Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Relevant CbC Regulations of an MNE Group means: (a) if the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located (the UPE jurisdiction ) does not have Country-by-Country Reporting regulations and the MNE Group is not required to file a Country-by-Country Report in any jurisdiction - the following documents:
(i) the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, as approved by the Council of the OECD and last amended on 7 January 2022;
(b) if paragraph (a) does not apply and the MNE Group is does not file a Country-by-Country Report in the UPE Jurisdiction - the Country-by-Country Reporting regulations of the surrogate parent entity jurisdiction (determined in accordance with the documents mentioned in subparagraphs (a)(i) and (ii) ); or (c) otherwise - the Country-by-Country Reporting regulations of the UPE jurisdiction.
(ii) Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 (Updated May 2024) of the OECD; or
8-195(2)
Country-by-Country Reporting regulations means any of the following: (a) Subdivision 815-E of the Income Tax Assessment Act 1997 (Reporting obligations for country by country reporting entities); (b) a law of a non-Australian jurisdiction corresponding to that Subdivision.
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