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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-4 - EFFECTIVE TAX RATE COMPUTATION FOR INVESTMENT ENTITIES  

Division 3 - Top-up Tax of Investment Entity etc.  

SECTION 7-110   MEANING OF ALLOCABLE GloBE INCOME OR LOSS  

7-110(1)    
An MNE Group ' s Allocable GloBE Income or Loss for an Investment Entity for a Fiscal Year is:

(a)    the Investment Entity ' s GloBE Income or Loss for the Fiscal Year; multiplied by:

(b)    the Inclusion Ratio of the Ultimate Parent Entity of the MNE Group for the Investment Entity for the Fiscal Year.

Note:

In computing that Inclusion Ratio, treat the Investment Entities as the only Constituent Entities of the MNE Group (see section 7-100 ).

7-110(2)    
For the purposes of this section, treat the Investment Entity as a Low-Taxed Constituent Entity.

7-110(3)    
For the purposes of this section:

(a)    treat references in section 2-15 to GloBE Income as references to GloBE Income or Loss; and

(b)    treat the reference in paragraph 2-15(2)(a) to net income as a reference to net income or loss.

 

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.