Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
2‑10 Meaning of Allocable Share2‑10 Meaning of Allocable Share
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2‑10 Meaning of Allocable Share
A Parent Entity’s Allocable Share of the Top‑up Tax of a Low‑Taxed Constituent Entity for a Fiscal Year is an amount equal to: (a) the Top‑up Tax of the Low‑Taxed Constituent Entity for the Fiscal Year; multiplied by: (b) the Parent Entity’s Inclusion Ratio for the Low‑Taxed Constituent Entity for the Fiscal Year.
Note 1: See section 2‑20 for the effect of the IIR offset mechanism on the Allocable Share.
Note 2: See section 7‑95 for the computation of a Parent Entity’s Allocable Share of the Top‑up Tax of a Constituent Entity that is an Investment Entity.