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 5-30  

5-30   MEANING OF JURISDICTIONAL TOP-UP TAX  
The Jurisdictional Top-up Tax 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):

(Top-up Tax Percentage × Excess Profit) + Additional Current Top-up Tax − Domestic Top-up Tax

where:

Additional Current Top-up Tax
is the sum of the amounts determined or treated as Additional Current Top-up Tax of the MNE Group for the jurisdiction for the Fiscal Year.

Domestic Top-up Tax
is the sum of the amounts payable by each Constituent Entity of the MNE Group under a Qualified Domestic Minimum Top-up Tax of the jurisdiction for the Fiscal Year.

Excess Profit
is the Excess Profit of the MNE Group for the jurisdiction for the Fiscal Year.

Top-up Tax Percentage
is the Top-up Tax Percentage of the MNE Group for the jurisdiction for the Fiscal Year.