Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
This section applies if: (a) an election under subsection 7-145(1) applies to:
(i) an Investment Entity that is a Constituent Entity of an MNE Group; and
(b) the Investment Entity has GloBE Income for the tested year.
(ii) a Fiscal Year (the tested year ); and
7-160(2)
At the end of the tested year, an Undistributed Net GloBE Income Account is established for the Investment Entity for the tested year.
7-160(3)
At the end of the tested year, the balance of the Undistributed Net GloBE Income Account is the Investment Entity ' s GloBE Income for the tested year, reduced (but not below zero) by applying the following against that balance: (a) the Investment Entity ' s Covered Taxes (if any) for the tested year; (b) distributions and deemed distributions in the tested year to shareholders other than Constituent Entities that are Investment Entities.
7-160(4)
For the purposes of subsection (5) , this subsection covers a Fiscal Year if the Fiscal Year is the first, second or third Fiscal Year after the tested year.
7-160(5)
At the end of a Fiscal Year covered by subsection (4) , reduce the balance of the Undistributed Net GloBE Income Account for the Investment Entity for the tested year (but not below zero) by applying the following against that balance: (a) the Investment Entity ' s Covered Taxes (if any) for the Fiscal Year; (b) distributions and deemed distributions in the Fiscal Year to shareholders other than Constituent Entities that are Investment Entities; (c) if the Investment Entity has a GloBE Loss for the Fiscal Year - the GloBE Loss; (d) if the Investment Entity has a GloBE Loss for a previous Fiscal Year covered by subsection (3) - the GloBE Loss, to the extent that it has not been applied under a previous operation of paragraph (c) or this paragraph.
7-160(6)
For the purposes of subsection (5) : (a) apply an amount mentioned in paragraph (5)(a) before applying an amount mentioned in paragraph (5)(b) ; and (b) apply an amount mentioned in paragraph (5)(b) before applying an amount mentioned in paragraph (5)(c) ; and (c) apply an amount mentioned in paragraph (5)(c) before applying an amount mentioned in paragraph (5)(d) .
7-160(7)
For the purposes of paragraph (5)(d) , apply a GloBE Loss for an earlier Fiscal Year before applying a GloBE Loss for a later Fiscal Year.
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