Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 7
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TAX NEUTRALITY AND DISTRIBUTION REGIMES
PART 7-4
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EFFECTIVE TAX RATE COMPUTATION FOR INVESTMENT ENTITIES
Division 3
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Top-up Tax of Investment Entity etc.
SECTION 7-110
MEANING OF ALLOCABLE GloBE INCOME OR LOSS
7-110(1)
An MNE Group ' s Allocable GloBE Income or Loss for an Investment Entity for a Fiscal Year is: (a) the Investment Entity ' s GloBE Income or Loss for the Fiscal Year; multiplied by: (b) the Inclusion Ratio of the Ultimate Parent Entity of the MNE Group for the Investment Entity for the Fiscal Year.
7-110(2)
For the purposes of this section, treat the Investment Entity as a Low-Taxed Constituent Entity.
7-110(3)
For the purposes of this section: (a) treat references in section 2-15 to GloBE Income as references to GloBE Income or Loss; and (b) treat the reference in paragraph 2-15(2)(a) to net income as a reference to net income or loss.
An MNE Group ' s Allocable GloBE Income or Loss for an Investment Entity for a Fiscal Year is: (a) the Investment Entity ' s GloBE Income or Loss for the Fiscal Year; multiplied by: (b) the Inclusion Ratio of the Ultimate Parent Entity of the MNE Group for the Investment Entity for the Fiscal Year.
Note:
In computing that Inclusion Ratio, treat the Investment Entities as the only Constituent Entities of the MNE Group (see section 7-100 ).
7-110(2)
For the purposes of this section, treat the Investment Entity as a Low-Taxed Constituent Entity.
7-110(3)
For the purposes of this section: (a) treat references in section 2-15 to GloBE Income as references to GloBE Income or Loss; and (b) treat the reference in paragraph 2-15(2)(a) to net income as a reference to net income or loss.
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