Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Qualified CbC Report in relation to a jurisdiction means a Country-by-Country Report that is prepared in relation to the jurisdiction, and filed, using Qualified Financial Statements.
8-35(2)
Subsections (3) and (4) apply if an MNE Group is not required have a Qualified CbC Report in relation to a jurisdiction.
8-35(3)
For the purposes of this Division, if: (a) the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located has requirements for the filing of Country-by-Country Reports; and (b) on the assumption that the MNE Group filed a Country-by-Country Report in accordance with those requirements, data from the MNE Group ' s Qualified Financial Statements would have been reported as total revenue and profit or loss before tax in that Country-by-Country Report;
treat that data as being reported in the MNE Group ' s Qualified CbC Report.
8-35(4)
For the purposes of this Division, if: (a) the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located does not have requirements for the filing of Country-by-Country Reports; and (b) on the assumption that the MNE Group filed a Country-by-Country Report in accordance with the following, data from the MNE Group ' s Qualified Financial Statements would have been reported as total revenue and profit or loss before tax in that Country-by-Country Report:
(i) Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report of the OECD/G20 Base Erosion and Profit Shifting Project;
(ii) Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 (Updated May 2024) of the OECD;
treat that data as being reported in the MNE Group ' s Qualified CbC Report.
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