Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Treat the Investment Entities mentioned in subsection 7-80(1) as not being Constituent Entities of the MNE Group, for the purposes of: (a) computing the Top-up Tax of each Constituent Entity (other than an Investment Entity) of the MNE Group; and (b) determining whether each Constituent Entity (other than an Investment Entity) of the MNE Group is a Low-Taxed Constituent Entity.
7-115(2)
Paragraph (1)(a) does not affect the operation of Chapters 2 , 3 , 4 (other than sections 4-30 and 4-35 , and Parts 4-5 and 4-6 ), 6 , 8 and 9 to the extent that they affect the application of Chapter 5 for the purposes of computing the Top-up Tax of each Constituent Entity (other than an Investment Entity) of the MNE Group.
7-115(3)
Subsection (4) applies if a Constituent Entity of the MNE Group that is not an Investment Entity has an amount payable for a Fiscal Year in respect of an Investment Entity under a Qualified Domestic Minimum Top-up Tax of a jurisdiction.
7-115(4)
In computing the Jurisdictional Top-up Tax of the MNE Group for the jurisdiction under section 5-30 , treat the amount as not being an amount payable by the Constituent Entity under a Qualified Domestic Minimum Top-up Tax of the jurisdiction (see definition of Domestic Top-up Tax in that section).
Note:
The amount is treated as an amount payable by the Investment Entity: see subsection 7-105(4) .
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.
