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: (a) treat an amount recognised as a decrease to the equity of the Constituent Entity attributable to a distribution paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital issued by the Constituent Entity as an expense; and (b) treat an amount recognised as an increase to the equity of the Constituent Entity attributable to a distribution received or receivable in respect of Additional Tier One Capital or Restricted Tier One Capital held by the Constituent Entity as income.
3-210(2)
An instrument issued by a Constituent Entity, pursuant to prudential regulatory requirements, that is convertible to equity or written down if a pre-specified trigger event occurs, and that has other features which are designed to aid loss absorbency in the event of a financial crisis, is: (a) if the requirements are applicable to the banking sector - Additional Tier One Capital ; or (b) if the requirements are applicable to the insurance sector - Restricted Tier One Capital .
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