Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
This section specifies conditions for the purposes of paragraph 12(1)(b) of the Act.
6-10(2)
An MNE Group (the demerged Group ) meets the conditions specified in this section for a Fiscal Year (the test year ) if: (a) an Applicable MNE Group demerges (see subsection (3) ) into 2 or more Groups; and (b) the demerged Group is one of those Groups; and (c) the demerged Group is an MNE Group throughout the test year; and (d) if the test year is the first Fiscal Year ending after the demerger - the demerged Group ' s annual revenue for the test year equals or exceeds its GloBE Threshold for the test year; and (e) if the test year is the second, third or fourth Fiscal Year ending after the demerger - in at least:
(i) the test year and a previous Fiscal Year ending after the demerger; or
(ii) two of the Fiscal Years ending after the demerger and before the test year;
the demerged Group has annual revenues equalling or exceeding its GloBE Threshold for the relevant year.
6-10(3)
For the purposes of this section, a demerger means any arrangement under which the Group Entities of a Group are separated into 2 or more Groups that are no longer consolidated with the same Ultimate Parent Entity.
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