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

CHAPTER 9 - TRANSITION RULES  

PART 9-3 - EXCLUSION FROM THE UTPR OF MNE GROUPS IN THE INITIAL PHASE OF THEIR INTERNATIONAL ACTIVITY  

SECTION 9-50   MEANING OF REFERENCE JURISDICTION  

9-50(1)    
The Reference Jurisdiction of an MNE Group is the jurisdiction where the MNE Group has the highest total value of tangible assets for the first Fiscal Year starting on or after 1 January 2024 for which the MNE Group is an Applicable MNE Group.

9-50(2)    
For the purposes of subsection (1) , the MNE Group ' s total value of tangible assets in a jurisdiction for a Fiscal Year is the sum of the Net Book Value of Tangible Assets for the Fiscal Year of each of the Constituent Entities of the MNE Group that are located in the jurisdiction.

9-50(3)    
For the purposes of subsection (2) , disregard a Constituent Entity of the MNE Group that is an Investment Entity.

9-50(4)    
For the purpose of this section, treat an Insurance Investment Entity as if it were an Investment Entity.