Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
Subsection (2) applies if a Constituent Entity of an MNE Group is: (a) the Ultimate Parent Entity of the MNE Group; and (b) subject to a Deductible Dividend Regime; and (c) where it is a Flow-through Entity - subsection 8-85(3) does not prevent section 8-10 from applying in relation to the MNE Group for the jurisdiction in which it is located for a Fiscal Year.
8-90(2)
For the purposes of section 8-10 , in working out the MNE Group ' s Profit (Loss) before Income Tax, and Simplified Covered Taxes, for the jurisdiction in which the Ultimate Parent Entity is located for the Fiscal Year, disregard amounts to the extent that they are distributed as a result of an Ownership Interest in the Ultimate Parent Entity held by a recipient described in paragraph 7-20(2)(a) , (b) or (c) .
Disclaimer and notice of copyright applicable to materials provided by CCH Australia Limited
CCH Australia Limited ("CCH") believes that all information which it has provided in this site is accurate and reliable, but gives no warranty of accuracy or reliability of such information to the reader or any third party. The information provided by CCH is not legal or professional advice. To the extent permitted by law, no responsibility for damages or loss arising in any way out of or in connection with or incidental to any errors or omissions in any information provided is accepted by CCH or by persons involved in the preparation and provision of the information, whether arising from negligence or otherwise, from the use of or results obtained from information supplied by CCH.
The information provided by CCH includes history notes and other value-added features which are subject to CCH copyright. No CCH material may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may download one copy for your personal use only, provided you keep intact all copyright and other proprietary notices. In particular, the reproduction of any part of the information for sale or incorporation in any product intended for sale is prohibited without CCH's prior consent.
