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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-3 - SUBSTANCE-BASED INCOME EXCLUSION  

SECTION 5-60   MEANING OF ELIGIBLE PAYROLL COSTS AND ELIGIBLE EMPLOYEE  

5-60(1)    
Eligible Payroll Costs means the following amounts, as recorded in financial accounts:

(a)    employee compensation expenditures, including salaries, wages, stock-based compensation and other expenditures that provide a direct and separate personal benefit to the employee (such as health insurance and pension contributions);

(b)    payroll and employment taxes;

(c)    employer social security contributions.

5-60(2)    
Eligible Employee of a Constituent Entity of an MNE Group means an individual who is:

(a)    an employee (including a part-time employee) of the Constituent Entity; or

(b)    an independent contractor participating in the ordinary operating activities of the MNE Group under the direction and control of one or more Constituent Entities of the MNE Group.