Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
In computing the GloBE Income or Loss for a Fiscal Year of a Constituent Entity of an MNE Group that is a Low-Tax Entity for the Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude any expense attributable to an Intragroup Financing Arrangement for the Fiscal Year that can reasonably be anticipated, over the expected duration of the arrangement, to: (a) increase the amount of expenses taken into account in computing the GloBE Income or Loss of the Low-Tax Entity for any Fiscal Year; and (b) not result in a corresponding increase in the taxable income of another Constituent Entity of the MNE Group that is a High-Tax Counterparty for the Fiscal Year.
3-180(2)
For the purposes of subsection (1) , in determining whether a Constituent Entity is a Low-Tax Entity for the Fiscal Year, disregard that subsection.
3-180(3)
For the purposes of paragraph (1)(b) , disregard an amount of increase if: (a) the High-Tax Counterparty is eligible for an exclusion, exemption, deduction, credit or other tax benefit under local law; and (b) it can reasonably be considered that the benefit is calculated by reference to the amount of the increase.
Disclaimer and notice of copyright applicable to materials provided by CCH Australia Limited
CCH Australia Limited ("CCH") believes that all information which it has provided in this site is accurate and reliable, but gives no warranty of accuracy or reliability of such information to the reader or any third party. The information provided by CCH is not legal or professional advice. To the extent permitted by law, no responsibility for damages or loss arising in any way out of or in connection with or incidental to any errors or omissions in any information provided is accepted by CCH or by persons involved in the preparation and provision of the information, whether arising from negligence or otherwise, from the use of or results obtained from information supplied by CCH.
The information provided by CCH includes history notes and other value-added features which are subject to CCH copyright. No CCH material may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may download one copy for your personal use only, provided you keep intact all copyright and other proprietary notices. In particular, the reproduction of any part of the information for sale or incorporation in any product intended for sale is prohibited without CCH's prior consent.
