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 4-110  

4-110   MEANING OF RECAPTURE EXCEPTION ACCRUAL  
A Recapture Exception Accrual means a tax expense accrued in the financial accounts of a Constituent Entity attributable to changes in associated deferred tax liabilities, in respect of any of the following:

(a)    cost recovery allowances on tangible assets;

(b)    the cost of a licence or similar arrangement from a government for the use of immovable property or exploitation of natural resources that entails significant investment in tangible assets;

(c)    research and development expenses;

(d)    de-commissioning and remediation expenses;

(e)    fair value accounting on unrealised net gains;

(f)    foreign currency exchange net gains;

(g)    insurance reserves and insurance policy deferred acquisition costs;

(h)    a gain that is:

(i) from the sale of tangible property located in the jurisdiction in which the Constituent Entity is located; and

(ii) reinvested in tangible property in that jurisdiction;

(i)    an additional amount accrued as a result of accounting principle changes with respect to a matter mentioned in any of paragraphs (a) to (h) .