Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Note:
Taxes on distributed profits, deemed profit distributions and non-business expenses imposed under an Eligible Distribution Tax System are Covered Taxes (see paragraph 4-40(1)(b) ).
SECTION 7-60 RECAPTURE ACCOUNT LOSS CARRY-FORWARD 7-60(1)Subsection (2) applies if: (a) there is a Net GloBE Loss for a Fiscal Year of an MNE Group for a jurisdiction; and (b) at the end of the Fiscal Year, the amount mentioned in paragraph 7-55(4)(b) (Net GloBE Loss for current year multiplied by Minimum Rate) in respect of that Net GloBE Loss has not been applied fully under subsection 7-55(4) ; and (c) there is at least one Deemed Distribution Tax Recapture Account for the jurisdiction for the MNE Group for an earlier Fiscal Year.
7-60(2)
At the end of the Fiscal Year: (a) a Recapture Account Loss Carry-forward is established for the Fiscal Year for the jurisdiction for the MNE Group; and (b) the balance of the Recapture Account Loss Carry-forward is the amount mentioned in paragraph 7-55(4)(b) , to the extent that it has not been so applied.
7-60(3)
Reduce a Recapture Account Loss Carry-forward for a Fiscal Year for a jurisdiction for an MNE Group to the extent that it is applied under 7-55(4)(c) .
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