Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Note:
The GloBE Loss Deferred Tax Asset of an MNE Group, or the GloBE Loss Deferred Tax Asset of an Ultimate Parent Entity of an MNE Group, to the extent that it is used, forms part of Additions to Covered Taxes under paragraph 4-15(b) or (c) .
SECTION 4-130 GloBE LOSS ELECTION FOR AN ULTIMATE PARENT ENTITY 4-130(1)A Filing Constituent Entity for an MNE Group may make an election for the Ultimate Parent Entity of an MNE Group under this subsection if: (a) the Ultimate Parent Entity is a Flow-through Entity; and (b) the jurisdiction in which it is located does not have an Eligible Distribution Tax System; and (c) the election is made in the first GloBE Information Return of the MNE Group for the first Fiscal Year in respect of which subsection 8-10(1) (Transitional CbCR Safe Harbour) does not apply in relation to the MNE Group, the jurisdiction and the Fiscal Year.
4-130(2)
Unless the GloBE Loss Election for the Ultimate Parent Entity made under subsection (1) is revoked, it applies to: (a) the Fiscal Year for which the GloBE Information Return for the Applicable MNE Group that records the election is filed by the Filing Constituent Entity; and (b) each subsequent Fiscal Year.
Revocation
4-130(3)
A Filing Constituent Entity for the MNE Group may revoke the GloBE Loss Election for the Ultimate Parent Entity made under subsection (1) .
4-130(4)
If the Filing Constituent Entity revokes a GloBE Loss Election for the Ultimate Parent Entity made under subsection (1) , the election does not apply to: (a) the Fiscal Year for which the GloBE Information Return for the Applicable MNE Group that records the revocation is filed by the Filing Constituent Entity; and (b) each subsequent Fiscal Year.
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