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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-3 - SUBSTANCE-BASED INCOME EXCLUSION  

SECTION 5-90   ALLOCATION OF AMOUNTS IN RELATION TO DEDUCTIBLE DIVIDEND REGIMES  

5-90(1)    
This section applies, in relation to a Fiscal Year, if:

(a)    the Ultimate Parent Entity of an MNE Group is subject to a Deductible Dividend Regime; and

(b)    the GloBE Income of a Constituent Entity of the MNE Group has been reduced by an amount for the Fiscal Year under subsection 7-20(2) or 7-25(3) .

5-90(2)    
For the purposes of sections 5-50 , 5-55 and 5-65 :

(a)    reduce the Eligible Payroll Costs accrued for the Fiscal Year of Eligible Employees of the Constituent Entity by multiplying it by the proportion the amount mentioned in paragraph (1)(b) bears to the Constituent Entity ' s GloBE Income for the Fiscal Year, before the reduction mentioned in that paragraph; and

(b)    reduce the carrying value for the Fiscal Year of the Eligible Tangible Assets of the Constituent Entity by multiplying it by the same proportion.