Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
An MNE Group ' s Profit (Loss) before Income Tax , for a jurisdiction for a Fiscal Year, means the MNE Group ' s profit or loss before income tax for the jurisdiction for the Fiscal Year, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year.
8-30(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.
8-30(3)
For the purposes of subsection (1) , include the amount of the intragroup payment in the MNE Group ' s profit or loss before income tax mentioned in that subsection.
8-30(4)
For the purposes of subsection (1) , if: (a) a Constituent Entity of the MNE Group is a Permanent Establishment; and (b) a loss arising in respect of the Permanent Establishment is allocated to the Permanent Establishment (and not to the Main Entity in respect of the Permanent Establishment);
increase the MNE Group ' s profit or loss before income tax for the jurisdiction in which the Main Entity is located by the amount of the loss.
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