Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
An MNE Group meets the Routine profits test for a jurisdiction for a Fiscal Year if the MNE Group ' s Profit (Loss) before Income Tax for the jurisdiction for the Fiscal Year is equal to or less than the MNE Group ' s Substance-based Income Exclusion Amount for the jurisdiction for the Fiscal Year.
8-60(2)
For the purposes of subsection (1) , in computing the Substance-based Income Exclusion Amount mentioned in that subsection, treat a Constituent Entity of the MNE Group as being located in the jurisdiction for the Fiscal Year if, and only if: (a) the Constituent Entity is a CbCR Resident of the jurisdiction for the Fiscal Year; and (b) the Constituent Entity is located in the jurisdiction for the Fiscal Year.
8-60(3)
To avoid doubt, for the purposes of subsection (1) , in computing the Substance-based Income Exclusion Amount mentioned in that subsection, apply the rules in Part 9-2 (Transitional relief for Substance-based Income Exclusion).
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