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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES  

PART 4-2 - DEFINITION OF COVERED TAXES  

SECTION 4-40   MEANING OF COVERED TAXES  

4-40(1)    
The Covered Taxes of a Constituent Entity of a Group means:

(a)    Taxes recorded in the financial accounts of the Constituent Entity in respect of:

(i) its income or profits; or

(ii) its share of the income or profits of a Constituent Entity of the Group, in which it holds an Ownership Interest; and

(b)    Taxes on distributed profits, deemed profit distributions and non-business expenses imposed under an Eligible Distribution Tax System; and

(c)    Taxes imposed in lieu of a generally applicable corporate income tax; and

(d)    Taxes levied by reference to retained earnings and corporate equity, including a Tax on multiple components based on income and equity.

4-40(2)    
Despite subsection (1) , Covered Taxes does not include any amount of the following:

(a)    Top-up Tax accrued by a Parent Entity under a Qualified IIR;

(b)    Top-up Tax accrued by a Constituent Entity under a Qualified Domestic Minimum Top-up Tax;

(c)    any Tax under or as a result of the application of a Qualified UTPR;

(d)    a Disqualified Refundable Imputation Tax;

(e)    Taxes paid or accrued by an insurance company in respect of returns to policyholders.