Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 8
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ADMINISTRATION
PART 8-2
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SAFE HARBOURS
Division 2
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Transitional CbCR Safe Harbour
Subdivision B
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De minimis test
SECTION 8-25
MEANING OF TOTAL REVENUE OF MNE GROUP
8-25(1)
An MNE Group ' s Total Revenue , for a jurisdiction for a Fiscal Year, means the MNE Group ' s total revenues in the jurisdiction, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year.
8-25(2)
Subsection (3) applies if an intragroup payment that is made between Group Entities of the MNE Group: (a) is treated as income in the Qualified Financial Statements of the recipient Group Entity; and (b) is treated as expense in the Qualified Financial Statements of the paying Group Entity.
8-25(3)
For the purposes of subsection (1) , include the amount of the intragroup payment in the MNE Group ' s total revenues mentioned in that subsection.
An MNE Group ' s Total Revenue , for a jurisdiction for a Fiscal Year, means the MNE Group ' s total revenues in the jurisdiction, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year.
8-25(2)
Subsection (3) applies if an intragroup payment that is made between Group Entities of the MNE Group: (a) is treated as income in the Qualified Financial Statements of the recipient Group Entity; and (b) is treated as expense in the Qualified Financial Statements of the paying Group Entity.
8-25(3)
For the purposes of subsection (1) , include the amount of the intragroup payment in the MNE Group ' s total revenues mentioned in that subsection.
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