Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Section 8-10 does not apply in relation to an MNE Group for a jurisdiction for a Fiscal Year if any of the following conditions are satisfied: (a) the jurisdiction is a jurisdiction in which a Stateless Constituent Entity is taken to be located under section 5-45 ; (b) the MNE Group is a combined MNE Group referred to in paragraph 6-80(2)(a) (Multi-Parented MNE Groups) and there is no single Qualified CbC Report that includes the information of the all the separate Groups referred to in that paragraph; (c) an election for the MNE Group under section 7-40 (Deemed Distribution Tax election) applies to the Fiscal Year and the jurisdiction; (d) all of the following conditions are satisfied:
(i) in a previous Fiscal Year, one or more Constituent Entities of the MNE Group were located in the jurisdiction;
(ii) section 8-10 did not apply in relation to the MNE Group for the jurisdiction for the previous Fiscal Year;
(iii) the MNE Group was an Applicable MNE Group for the previous Fiscal Year.
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