Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Subsections (2) and (3) apply if: (a) a Constituent Entity of an MNE Group is a CbCR Resident of a jurisdiction; and (b) an amount in respect of a Fiscal Year is ascertained for the purposes of this Part in relation to the Constituent Entity; and (c) the amount is ascertained by reference to Qualified Financial Statements of the MNE Group to the extent that they relate to the Constituent Entity.
8-75(2)
Ascertain any other amount that is: (a) in respect of the Fiscal Year; and (b) for the purposes of this Part; and (c) in relation to the Constituent Entity;
by reference to the same Qualified Financial Statements.
8-75(3)
In ascertaining an amount in respect of the Fiscal Year for the purposes of this Part in relation to another Constituent Entity of the MNE Group that is a CbCR Resident of the jurisdiction, the following rules apply: (a) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8-70(1)(a) - disregard paragraphs 8-70(1)(b) and (c) ; (b) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8-70(1)(b) - disregard paragraphs 8-70(1)(a) and (c) ; (c) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8-70(1)(c) - disregard paragraphs 8-70(1)(a) and (b) .
8-75(4)
A reference in this section to Constituent Entity does not include a reference to: (a) a Permanent Establishment; or (b) an NMCE for the Fiscal Year.
8-75(5)
A reference in this section to an amount does not include a reference to the deferred tax component of income tax expense.
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