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 5-25  

5-25   MEANING OF EXCESS PROFIT  
The Excess Profit of an MNE Group for a jurisdiction for a Fiscal Year is the amount computed in accordance with the following formula (but not less than zero):

Net GloBE Income − Substance-based Income Exclusion amount

where:

Net GloBE Income
is the Net GloBE Income of the MNE Group for the jurisdiction for the Fiscal Year.

Substance-based Income Exclusion Amount
is the Substance-based Income Exclusion Amount of the MNE Group for the jurisdiction for the Fiscal Year.