Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 3 - COMPUTATION OF GloBE INCOME OR LOSS  

PART 3-2 - ADJUSTMENTS TO DETERMINE GloBE INCOME OR LOSS  

Division 2 - Other Article 3.2 adjustments  

SECTION 3-185  

3-185   MEANING OF INTRAGROUP FINANCING ARRANGEMENT  
An Intragroup Financing Arrangement for a Fiscal Year is an arrangement in respect of which all of the following apply:

(a)    the arrangement is entered into between 2 or more Constituent Entities of an MNE Group;

(b)    under the arrangement, one of the Constituent Entities (the investor ) directly or indirectly provides credit to, or otherwise makes an investment in, another of the Constituent Entities (the recipient );

(c)    the investor is a High-Tax Counterparty for the Fiscal Year;

(d)    the recipient is a Low-Tax Entity for the Fiscal Year.