Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
View history note
Hide history noteAn MNE Group ' s Jurisdictional Top-up Tax for a jurisdiction for a Fiscal Year is taken to be zero if: (a) the jurisdiction applies a Qualified Domestic Minimum Top-up Tax for the Fiscal Year; and (b) the jurisdiction is specified in a determination under subsection (2) ; and (c) an election for the MNE Group under subsection (3) applies to the jurisdiction and the Fiscal Year.
Note:
The condition in paragraph (b) will not be satisfied if the jurisdiction is a jurisdiction in which a Stateless Constituent Entity is taken to be located under section 5-45 .
8-200(2)
The Minister may, by legislative instrument, make a determination specifying a jurisdiction if the Minister is satisfied that the jurisdiction ' s Qualified Domestic Minimum Top-up Tax has QDMTT Safe Harbour status for the Fiscal Year.
Election
8-200(3)
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to a specified jurisdiction.
Note:
A Filing Constituent Entity for an MNE Group may not make an election under this subsection in certain circumstances: see sections 8-205 and 8-210 .
8-200(4)
An election under subsection (3) is an Annual Election.
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