Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Note:
The Jurisdictional Top-up Tax or the Top-up Tax Percentage of an MNE Group for a jurisdiction may be modified by Part 8-2 (Safe harbours).
SECTION 5-30 5-30 MEANING OF JURISDICTIONAL TOP-UP TAXThe Jurisdictional Top-up Tax of an MNE Group for a jurisdiction for a Fiscal Year is the amount computed in accordance with the following formula (but not less than zero):
| (Top-up Tax Percentage × Excess Profit) + Additional Current Top-up Tax − Domestic Top-up Tax |
where:
Additional Current Top-up Tax
is the sum of the amounts determined or treated as Additional Current Top-up Tax of the MNE Group for the jurisdiction for the Fiscal Year.
Domestic Top-up Tax
is the sum of the amounts payable by each Constituent Entity of the MNE Group under a Qualified Domestic Minimum Top-up Tax of the jurisdiction for the Fiscal Year.
Excess Profit
is the Excess Profit of the MNE Group for the jurisdiction for the Fiscal Year.
Top-up Tax Percentage
is the Top-up Tax Percentage of the MNE Group for the jurisdiction for the Fiscal Year.
Disclaimer and notice of copyright applicable to materials provided by CCH Australia Limited
CCH Australia Limited ("CCH") believes that all information which it has provided in this site is accurate and reliable, but gives no warranty of accuracy or reliability of such information to the reader or any third party. The information provided by CCH is not legal or professional advice. To the extent permitted by law, no responsibility for damages or loss arising in any way out of or in connection with or incidental to any errors or omissions in any information provided is accepted by CCH or by persons involved in the preparation and provision of the information, whether arising from negligence or otherwise, from the use of or results obtained from information supplied by CCH.
The information provided by CCH includes history notes and other value-added features which are subject to CCH copyright. No CCH material may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may download one copy for your personal use only, provided you keep intact all copyright and other proprietary notices. In particular, the reproduction of any part of the information for sale or incorporation in any product intended for sale is prohibited without CCH's prior consent.
