Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 2
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LIABILITY AMOUNTS
PART 2-2
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ALLOCATION OF TOP-UP TAX UNDER THE IIR
SECTION 2-10
2-10
MEANING OF ALLOCABLE SHARE
A Parent Entity ' s Allocable Share of the Top-up Tax of a Low-Taxed Constituent Entity for a Fiscal Year is an amount equal to: (a) the Top-up Tax of the Low-Taxed Constituent Entity for the Fiscal Year;
A Parent Entity ' s Allocable Share of the Top-up Tax of a Low-Taxed Constituent Entity for a Fiscal Year is an amount equal to: (a) the Top-up Tax of the Low-Taxed Constituent Entity for the Fiscal Year;
multiplied by:
(b) the Parent Entity ' s Inclusion Ratio for the Low-Taxed Constituent Entity for the Fiscal Year.Note 1:
See section 2-20 for the effect of the IIR offset mechanism on the Allocable Share.
Note 2:
See section 7-95 for the computation of a Parent Entity ' s Allocable Share of the Top-up Tax of a Constituent Entity that is an Investment Entity.
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