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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES  

PART 4-1 - ADJUSTED COVERED TAXES  

Division 1 - General  

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SECTION 4-15  

4-15   MEANING OF ADDITIONS TO COVERED TAXES  
The Additions to Covered Taxes for a Fiscal Year of a Constituent Entity of an MNE Group is the sum of the following:

(a)    the amount (if any) of Covered Taxes of the Constituent Entity for the Fiscal Year accrued as an expense in the profit before taxation in the Constituent Entity ' s financial accounts for the Fiscal Year;

(b)    if:


(i) there is a GloBE Loss Deferred Tax Asset of the MNE Group for the jurisdiction in which the Constituent Entity is located; and

(ii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4-125(2) ; and

(iii) if there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity of the MNE Group - the Constituent Entity is not the Ultimate Parent Entity;
the Constituent Entity ' s share of that amount, computed based on the Constituent Entity ' s share of the MNE Group ' s Net GloBE Income for the Fiscal Year;

(c)    if:


(i) the Constituent Entity is the Ultimate Parent Entity of the MNE Group; and

(ii) there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity; and

(iii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4-135(2) ;
that amount;

(d)    the amount (if any) of Covered Taxes of the Constituent Entity for the Fiscal Year that is paid in the Fiscal Year, to the extent that the amount:


(i) relates to an uncertain tax position; and

(ii) was treated as a Reduction to Covered Taxes of the Constituent Entity for a previous Fiscal Year under paragraph 4-20(1)(e) ;

(e)    the amount (if any) of credit or refund, in respect of a Qualified Refundable Tax Credit or Marketable Transferable Tax Credit, that is recorded as a reduction, in respect of Covered Taxes, to its Accrued Current Covered Tax Expense for the Fiscal Year.

 

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