Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
For the purposes of applying subsection 8-10(1) in relation to an MNE Group and a jurisdiction: (a) exclude from the MNE Group ' s profit or loss before income tax for the jurisdiction any expense or loss arising as a result of a deduction/non-inclusion arrangement, or duplicate loss arrangement, entered into after 15 December 2022; and (b) exclude from the MNE Group ' s income tax expense for the jurisdiction any income tax expense arising as a result of a duplicate tax recognition arrangement entered into after 15 December 2022.
8-110(2)
Subsections (3) and (4) apply if: (a) the expense or loss mentioned in paragraph (1)(a) arises as a result of an arrangement that is a duplicate loss arrangement; and (b) the arrangement is a duplicate loss arrangement because of paragraph 8-125(1)(a) ; and (c) all Constituent Entities of the MNE Group including the expense or loss in their financial statements are located in the same jurisdiction.
8-110(3)
A Filing Constituent Entity for the MNE Group must choose one of the Constituent Entities for the purposes of subsection (4) .
8-110(4)
Treat subsection (1) as not applying with respect to the expense or loss in the financial statements of that Constituent Entity.
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