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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-3 - SUBSTANCE-BASED INCOME EXCLUSION  

SECTION 5-90   ALLOCATION OF AMOUNTS IN RELATION TO DEDUCTIBLE DIVIDEND REGIMES  

5-90(1)    
This section applies, in relation to a Fiscal Year, if:

(a)    the Ultimate Parent Entity of an MNE Group is subject to a Deductible Dividend Regime; and

(b)    the GloBE Income of a Constituent Entity of the MNE Group has been reduced by an amount for the Fiscal Year under subsection 7-20(2) or 7-25(3) .

5-90(2)    
For the purposes of sections 5-50 , 5-55 and 5-65 :

(a)    reduce the Eligible Payroll Costs accrued for the Fiscal Year of Eligible Employees of the Constituent Entity by multiplying it by the proportion the amount mentioned in paragraph (1)(b) bears to the Constituent Entity ' s GloBE Income for the Fiscal Year, before the reduction mentioned in that paragraph; and

(b)    reduce the carrying value for the Fiscal Year of the Eligible Tangible Assets of the Constituent Entity by multiplying it by the same proportion.


 

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.