Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Subsection (2) applies if: (a) either of the following is a subsidiary member of a consolidated group:
(i) a Constituent Entity of an MNE Group;
(b) the head company of the consolidated group is not an Excluded Entity or a Securitisation Entity for the Fiscal Year.
(ii) a JV Subsidiary of a Joint Venture of an MNE Group; and
2-40(2)
Despite section 2-30 , the Constituent Entity ' s or the JV Subsidiary ' s (as the case requires) Domestic Top-up Tax Amount for the Fiscal Year is taken to be reduced to zero.
2-40(3)
Subsection (4) applies if: (a) any of the following is the head company of a consolidated group:
(i) a Constituent Entity of an MNE Group;
(ii) a Joint Venture of an MNE Group;
(b) the head company of the consolidated group is not an Excluded Entity or a Securitisation Entity for the Fiscal Year.
(iii) a JV Subsidiary of a Joint Venture of an MNE Group; and
2-40(4)
The amount of the head company ' s Domestic Top-up Tax Amount for the Fiscal Year is taken to be increased by the amount of each reduction under subsection (2) of this section (if any) in respect of a subsidiary member of the consolidated group.
2-40(5)
This section applies in relation to a MEC group in the same way in which it applies in relation to a consolidated group.
2-40(6)
The following terms have the same meaning in this section as they do in the Income Tax Assessment Act 1997 : (a) consolidated group; (b) head company; (c) MEC group; (d) subsidiary member.
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