Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 2 - Transitional CbCR Safe Harbour  

Subdivision B - De minimis test  

SECTION 8-25   MEANING OF TOTAL REVENUE OF MNE GROUP  

8-25(1)    
An MNE Group ' s Total Revenue , for a jurisdiction for a Fiscal Year, means the MNE Group ' s total revenues in the jurisdiction, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year.

8-25(2)    
Subsection (3) applies if an intragroup payment that is made between Group Entities of the MNE Group:

(a)    is treated as income in the Qualified Financial Statements of the recipient Group Entity; and

(b)    is treated as expense in the Qualified Financial Statements of the paying Group Entity.

8-25(3)    
For the purposes of subsection (1) , include the amount of the intragroup payment in the MNE Group ' s total revenues mentioned in that subsection.

 

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