Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Eligible Tangible Asset , of a Constituent Entity located in a jurisdiction, means any of the following: (a) property (including plant and equipment) located in the jurisdiction that are owned by the Constituent Entity; (b) natural resources located in the jurisdiction that are owned by the Constituent Entity; (c) the Constituent Entity ' s right of use, as a lessee, of tangible assets located in the jurisdiction; (d) a licence or similar arrangement from a government for the use by the Constituent Entity of immovable property in the jurisdiction, or exploitation of natural resources in the jurisdiction, that entails significant investment in tangible assets.
5-75(2)
If the Constituent Entity holds part of a property mentioned in paragraph (1)(a) for lease and retains the other part of the property for its own use: (a) for the purposes of this Part, treat the parts of the property as separate Eligible Tangible Assets ; and (b) allocate the carrying value of the property between those parts on a just and reasonable basis.
5-75(3)
However, an asset is not an Eligible Tangible Asset at any time during a Fiscal Year if it is used in the generation of a Constituent Entity ' s International Shipping Income for the Fiscal Year.
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