Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
The Payroll Carve-out Amount for a Constituent Entity of an MNE Group located in a jurisdiction, for a Fiscal Year, is computed as follows: (a) first, compute the total amount of Eligible Payroll Costs accrued for the Fiscal Year of Eligible Employees of the Constituent Entity; (b) next, exclude from that total amount the Eligible Payroll Costs, to the extent they are:
(i) capitalised and included in the carrying value of Eligible Tangible Assets for the Fiscal Year of a Constituent Entity of the MNE Group; or
(c) next, multiply the result of paragraph (b) by 5%.
(ii) included in the Constituent Entity ' s International Shipping Income Costs or Ancillary International Shipping Income Costs for the Fiscal Year, and excluded from the computation of the Constituent Entity ' s GloBE Income or Loss for the Fiscal Year under section 3-220 ;
5-55(2)
However, for the purposes of paragraph (1)(a) , if, in the Fiscal Year: (a) an Eligible Employee performs activities for the MNE Group both in the jurisdiction and outside the jurisdiction; and (b) the proportion of the Eligible Employee ' s time spent performing those activities in the jurisdiction is 50% or less;
reduce the Eligible Payroll Costs accrued for the Fiscal Year of the Eligible Employee by multiplying it by that proportion.
5-55(3)
For the purposes of paragraph (1)(a) , if a Filing Constituent Entity for an MNE Group chooses, under subsection (4) , to exclude certain Eligible Payroll Costs for certain Eligible Employees from the computation mentioned in that paragraph, exclude those Eligible Payroll Costs in computing the total amount mentioned in that paragraph.
5-55(4)
For the purposes of subsection (3) , a Filing Constituent Entity for an MNE Group may choose to exclude some or all Eligible Payroll Costs for some or all Eligible Employees from the computation mentioned paragraph (1)(a) by excluding relevant amounts from the MNE Group ' s GloBE Information Return 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.
