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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES  

PART 4-4 - MECHANISM TO ADDRESS TEMPORARY DIFFERENCES  

Note:

SECTION 4-115   MEANING OF DISALLOWED ACCRUAL AND UNCLAIMED ACCRUAL  

4-115(1)    
A Disallowed Accrual , of a Constituent Entity of an MNE Group for a Fiscal Year, means a movement in deferred tax expense accrued in the financial accounts of the Constituent Entity for the Fiscal Year that relates to:

(a)    an uncertain tax position; or

(b)    distributions from any Constituent Entity of the MNE Group (whether or not the Constituent Entity mentioned previously in this subsection).

4-115(2)    
An Unclaimed Accrual , of a Constituent Entity of an MNE Group for a Fiscal Year, means an increase in a deferred tax liability recorded in the financial accounts of the Constituent Entity for the Fiscal Year (the current year ) if:

(a)    it is not expected to be reversed by the end of the fifth following Fiscal Year; and

(b)    an election under subsection (3) applies to the Constituent Entity for the current year.

Election

4-115(3)    
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.

4-115(4)    
An election under subsection (3) is an Annual Election.