Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
A duplicate loss arrangement is an arrangement that results in an expense or loss being included in the financial statements of a Constituent Entity of an MNE Group located in a jurisdiction to the extent that: (a) the expense or loss is also included as an expense or loss in the financial statements of another Constituent Entity of the MNE Group; or (b) the arrangement also gives rise to a duplicate amount that is deductible for purposes of determining the taxable income of another Constituent Entity of the MNE Group located in another jurisdiction.
8-125(2)
Despite paragraph (1)(a) , an arrangement is not a duplicate loss arrangement to the extent that the amount of the expense or loss is offset against revenue which is included in the financial statements of both Constituent Entities.
8-125(3)
Despite paragraph (1)(b) , an arrangement is not a duplicate loss arrangement to the extent that the amount of the expense or loss is offset against revenue or income which is included in both: (a) the financial statements of the Constituent Entity including the expense or loss in its financial statements; and (b) the taxable income of the Constituent Entity claiming the deduction for the relevant expense or loss.
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