Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
A Refundable Tax Credit is a Qualified Refundable Tax Credit to the extent that it must be paid as cash or available as cash equivalents within 4 years from when a Constituent Entity first satisfies the conditions for receiving the credit under the laws of the jurisdiction granting the credit.
3-125(2)
However, the Refundable Tax Credit is not a Qualified Refundable Tax Credit : (a) if it is issued under a tax credit regime with a refund mechanism that has no practical significance for those taxpayers that will be entitled to the tax credit; or (b) to the extent that it includes an amount of Tax creditable or refundable under a Qualified Imputation Tax or a Disqualified Refundable Imputation Tax.
3-125(3)
A Non-Qualified Refundable Tax Credit is a Refundable Tax Credit that is not a Qualified Refundable Tax Credit or a Marketable Transferable Tax Credit.
3-125(4)
A tax credit is a Refundable Tax Credit if it is payable in cash or cash equivalents (including by way of discharge against a liability to a Tax which is not a Covered Tax): (a) after it has been used to reduce or discharge any liability to Covered Taxes; or (b) in the absence of any liability for Covered Taxes.
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