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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES  

PART 4-3 - ALLOCATION OF COVERED TAXES FROM ONE CONSTITUENT ENTITY TO ANOTHER CONSTITUENT ENTITY  

SECTION 4-50  

4-50   ALLOCATION OF AMOUNTS FROM TAX TRANSPARENT ENTITY TO A CONSTITUENT ENTITY-OWNER OF THE TAX TRANSPARENT ENTITY  
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity that is a Tax Transparent Entity to a Constituent Entity-owner of the Tax Transparent Entity if the amount is:

(a)    

either:

(i) accrued in the financial accounts of the Tax Transparent Entity for the Fiscal Year; or

(ii) allocated to the Tax Transparent Entity under section 4-55 (Allocation of amounts from Constituent Entity-owner to CFC); and

(b)    

so accrued or allocated in respect of the GloBE Income or Loss allocated to the Constituent Entity-owner under paragraph 3-255(1)(c) .