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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES

PART 4-4 - MECHANISM TO ADDRESS TEMPORARY DIFFERENCES

Note:

The Total Deferred Tax Adjustment Amount is added to Adjusted Covered Taxes under paragraph 4-5(b) .

SECTION 4-100

4-100 EFFECT OF RECAPTURED DEFERRED TAX LIABILITY
If there is Recaptured Deferred Tax Liability for a Constituent Entity of an MNE Group located in a jurisdiction for a Fiscal Year:

(a) for the purposes of section 4-20 , treat the amount of the Recaptured Deferred Tax Liability as increasing the Reduction to Covered Taxes of the Constituent Entity for the fifth preceding Fiscal Year; and

(b) recalculate the Effective Tax Rate and Jurisdictional Top-up Tax of the MNE Group for the jurisdiction for the fifth preceding Fiscal Year in accordance with section 5-95 .

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