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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-2 - TOP-UP TAX  

Note:

The Jurisdictional Top-up Tax or the Top-up Tax Percentage of an MNE Group for a jurisdiction may be modified by Part 8-2 (Safe harbours).

SECTION 5-20   MEANING OF TOP-UP TAX PERCENTAGE  

5-20(1)    
Subsection (2) applies in relation to an MNE Group for a jurisdiction for a Fiscal Year if it has an Effective Tax Rate for the jurisdiction for the Fiscal Year.

5-20(2)    
The Top-up Tax Percentage of the MNE Group for the jurisdiction for the Fiscal Year is the amount computed in accordance with the following formula (but not less than zero):

Minimum Rate − ETR

where:

ETR
is the Effective Tax Rate of the MNE Group for the jurisdiction for the Fiscal Year.