Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
In computing a Constituent Entity ' s GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to reverse any debits or credits in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year in respect of the following: (a) Covered Taxes (including Covered Taxes on income that is excluded in computing the GloBE Income or Loss); (b) to the extent it is not included in paragraph (a) , a deferred tax asset attributable to a loss for the Fiscal Year; (c) IIR; (d) Qualified Domestic Minimum Top-up tax; (e) UTPR; (f) Disqualified Refundable Imputation Tax; (g) Tax paid or accrued by an insurance company in respect of returns to policyholders to the extent that 3-205 applies in relation to those taxes.
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