Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Note:
The Total Deferred Tax Adjustment Amount is added to Adjusted Covered Taxes under paragraph 4-5(b) .
SECTION 4-90 TOTAL DEFERRED TAX ADJUSTMENT AMOUNT - EFFECT OF SUBSTITUTE LOSS CARRY-FORWARD DTA 4-90(1)This section applies if a Constituent Entity of an MNE Group has a Substitute Loss Carry-forward DTA.
4-90(2)
Subsection (3) applies if the Substitute Loss Carry-forward DTA is a Substitute Loss Carry-forward DTA under subsection 4-95(2) .
4-90(3)
For the purposes of computing the Total Deferred Tax Adjustment Amount of the Constituent Entity for a Fiscal Year, treat the Substitute Loss Carry-forward DTA as a deferred tax asset in computing the relevant deferred tax expense mentioned in subsection 4-85(1) in relation to the Fiscal Year.
4-90(4)
In computing the relevant deferred tax expense mentioned in subsection (3) , take account of the Substitute Loss Carry-forward DTA only to the extent the foreign tax credit that gave rise to the Substitute Loss Carry-forward DTA is used to offset tax liability on income included in the Constituent Entity ' s GloBE Income or Loss.
4-90(5)
Paragraph 4-85(2)(e) does not apply in relation to the Substitute Loss Carry-forward DTA.
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