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

CHAPTER 3 - COMPUTATION OF GloBE INCOME OR LOSS  

PART 3-4 - ALLOCATION OF INCOME OR LOSS BETWEEN A MAIN ENTITY AND A PERMANENT ESTABLISHMENT  

SECTION 3-245  

3-245   ADJUSTMENT OF PERMANENT ESTABLISHMENT ' S FINANCIAL ACCOUNTING NET INCOME OR LOSS  
Adjust the amount that would be, disregarding this section, a Permanent Establishment ' s Financial Accounting Net Income or Loss to reflect only the amounts of income and expense that are (or, if paragraph (c) applies, would be) attributable to the Permanent Establishment in accordance with:

(a)    if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(a) of the Act - the Tax Treaty applicable to the Permanent Establishment; or

(b)    if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(b) of the Act - the law of the jurisdiction in which the Permanent Establishment is located; or

(c)    if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(c) of the Act - Article 7 of the OECD Model Tax Convention.