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 1 - Article 3.2.1 adjustments  

SECTION 3-20   ADJUSTMENT - EXCLUDED DIVIDENDS  

3-20(1)    
In computing a Constituent Entity ' s GloBE Income or Loss for a Fiscal Year:

(a)    adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude any Excluded Dividends received or accrued by the Constituent Entity in the Fiscal Year; and

(b)    if an election under subsection (2) applies to the Constituent Entity and the Fiscal Year - for the purposes of this section and the definition of Excluded Dividends in subsection 3-25(1) , treat a Portfolio Shareholding of the Constituent Entity as a Short-term Portfolio Shareholding of the Constituent Entity.

Election

3-20(2)    
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to a specified Constituent Entity of the MNE Group.

3-20(3)    
An election under subsection (2) is a Five-Year Election.