Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Subsection (2) applies if an election for an MNE Group under subsection (3) applies to a Fiscal Year and the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located (the UPE jurisdiction ).
8-225(2)
In computing the Total UTPR Top-up Tax Amount for the MNE Group for the Fiscal Year, treat the following as being zero: (a) the Top-up Tax for the Fiscal Year of each Low-Taxed Constituent Entity for the Fiscal Year of the MNE Group that is located in the UPE jurisdiction; (b) if there are one or more Joint Ventures of the MNE Group - the Ultimate Parent Entity ' s Allocable Share of the Top-up Tax of each Joint Venture, and of each of its JV Subsidiaries (if any), that is located in the UPE jurisdiction.
Election
8-225(3)
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to the Fiscal Year and the UPE jurisdiction if: (a) the Fiscal Year:
(i) does not exceed 12 months; and
(ii) starts on or before 31 December 2025; and
(b) the UPE jurisdiction has a corporate income tax that applies at a rate of at least 20%.
(iii) ends before 31 December 2026; and
8-225(4)
An election under subsection (3) is an Annual Election.
Disclaimer and notice of copyright applicable to materials provided by CCH Australia Limited
CCH Australia Limited ("CCH") believes that all information which it has provided in this site is accurate and reliable, but gives no warranty of accuracy or reliability of such information to the reader or any third party. The information provided by CCH is not legal or professional advice. To the extent permitted by law, no responsibility for damages or loss arising in any way out of or in connection with or incidental to any errors or omissions in any information provided is accepted by CCH or by persons involved in the preparation and provision of the information, whether arising from negligence or otherwise, from the use of or results obtained from information supplied by CCH.
The information provided by CCH includes history notes and other value-added features which are subject to CCH copyright. No CCH material may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may download one copy for your personal use only, provided you keep intact all copyright and other proprietary notices. In particular, the reproduction of any part of the information for sale or incorporation in any product intended for sale is prohibited without CCH's prior consent.
