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 4-65   ALLOCATION OF AMOUNTS FROM CONSTITUENT ENTITY-OWNER TO HYBRID ENTITY OR REVERSE HYBRID ENTITY  

4-65(1)    
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity-owner of a Constituent Entity that is a Hybrid Entity to the Hybrid Entity if:

(a)    the Constituent Entity-owner holds an Ownership Interest in the Hybrid Entity; and

(b)    the amount is:

(i) accrued in the financial accounts of the Constituent Entity-owner for the Fiscal Year; and

(ii) so accrued in respect of income of the Hybrid Entity.

4-65(2)    
Subsection (1) applies in relation to a Constituent Entity-owner and a Constituent Entity that is a Reverse Hybrid Entity in the same way that it applies in relation to a Constituent Entity-owner and a Hybrid Entity.