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

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 2 - Transitional CbCR Safe Harbour  

Subdivision C - Simplified ETR test  

SECTION 8-50   MEANING OF SIMPLIFIED COVERED TAXES  

8-50(1)    
An MNE Group ' s Simplified Covered Taxes for a jurisdiction for a Fiscal Year is its income tax expense for the jurisdiction for the Fiscal Year that would be reported in its Qualified Financial Statements for the Fiscal Year, if the assumption in subsection (2) were made.

8-50(2)    
For the purposes of subsection (1) , assume that the following were disregarded:

(a)    if the income or loss of a Constituent Entity of the MNE Group is not included in the MNE Group ' s Qualified CbC Report in relation to the jurisdiction for the Fiscal Year - income tax expense for that Constituent Entity;

(b)    taxes that are not Covered Taxes;

(c)    uncertain tax positions.