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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-3 - ELIGIBLE DISTRIBUTION TAX SYSTEMS  

Note:

SECTION 7-60   RECAPTURE ACCOUNT LOSS CARRY-FORWARD  

7-60(1)    
Subsection (2) applies if:

(a)    there is a Net GloBE Loss for a Fiscal Year of an MNE Group for a jurisdiction; and

(b)    at the end of the Fiscal Year, the amount mentioned in paragraph 7-55(4)(b) (Net GloBE Loss for current year multiplied by Minimum Rate) in respect of that Net GloBE Loss has not been applied fully under subsection 7-55(4) ; and

(c)    there is at least one Deemed Distribution Tax Recapture Account for the jurisdiction for the MNE Group for an earlier Fiscal Year.

7-60(2)    
At the end of the Fiscal Year:

(a)    a Recapture Account Loss Carry-forward is established for the Fiscal Year for the jurisdiction for the MNE Group; and

(b)    the balance of the Recapture Account Loss Carry-forward is the amount mentioned in paragraph 7-55(4)(b) , to the extent that it has not been so applied.

7-60(3)    
Reduce a Recapture Account Loss Carry-forward for a Fiscal Year for a jurisdiction for an MNE Group to the extent that it is applied under 7-55(4)(c) .