Taxation (Multinational - Global and Domestic Minimum Tax) Amendment (2025 Measures No. 1) Rules 2025 (F2025L01550)

Schedule 1   Amendments

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

2   Subsection 2-35(5)

Repeal the subsection, substitute:

(5) If subsection (3) applies and no Constituent Entity of the MNE Group that is located in Australia and is not a Securitisation Entity has GloBE Income for the Fiscal Year:

(a) treat the GloBE Income of each such Constituent Entity as being one Euro for the Fiscal Year, for the purposes of the following:

(i) the definition of Aggregate GloBE Income of all CEs in subsection 5-40(2);

(ii) the definition of Aggregate GloBE Income of all CEs for prior year in subsection 5-40(5) (including that definition as it applies for the purposes of subsection 5-40(7));

(iii) the definition of GloBE Income of the CE in subsection 5-40(2);

(iv) the definition of GloBE Income of the CE for prior year in subsection 5-40(5) (including that definition as it applies for the purposes of subsection 5-40(7)); and

(b) for those purposes, do not apply paragraph 5-40(7)(b) in relation to the GloBE Income of the Constituent Entity for the Fiscal Year.