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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-3 - ELIGIBLE DISTRIBUTION TAX SYSTEMS  

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 7-70  

7-70   DISTRIBUTION TAXES EXCLUDED IN ADJUSTED COVERED TAXES  
In computing the Adjusted Covered Taxes for a Fiscal Year of the Constituent Entities of an MNE Group that are located in a jurisdiction, exclude the amount of Taxes mentioned in paragraph 4-40(1)(b) paid in relation to actual or deemed distributions by those Constituent Entities during the Fiscal Year, to the extent this amount is applied under paragraph 7-55(4)(a) .


 

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