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  

SECTION 4-30   ADDITIONAL CURRENT TOP-UP TAX WHERE MNE GROUP HAS NO NET GloBE INCOME AND TAX FALLS SHORT OF EXPECTED TAX  

4-30(1)    
Subsection (2) applies if:

(a)    an MNE Group has a Net GloBE Loss for a jurisdiction for a Fiscal Year; and

(b)    the sum of the Adjusted Covered Taxes for the Fiscal Year of each Constituent Entity of the MNE Group located in the jurisdiction is less than zero; and

(c)    that sum falls short of the Expected Adjusted Covered Taxes Amount computed under subsection (2) .

4-30(2)    
For the purposes of paragraph (1)(c) , the Expected Adjusted Covered Taxes Amount is:

(a)    the Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year;

multiplied by:

(b)    the Minimum Rate.

4-30(3)    
Treat the amount of the shortfall mentioned in paragraph (1)(c) as an amount of Additional Current Top-up Tax of the MNE Group for the Fiscal Year for the jurisdiction, in respect of that Fiscal Year.