Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
2‑20 IIR offset mechanism2‑20 IIR offset mechanism
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2‑20 IIR offset mechanism
(1) A Parent Entity of an MNE Group’s Allocable Share of the Top‑up Tax of a Low‑Taxed Constituent Entity is reduced if: (a) the Parent Entity holds an Indirect Ownership Interest in the Low‑Taxed Constituent Entity through an Intermediate Parent Entity or a Partially‑Owned Parent Entity of the MNE Group; and (b) the Intermediate Parent Entity or a Partially‑Owned Parent Entity is not eligible for an exclusion under subsection 2‑5(5), or an equivalent law of a non‑Australian jurisdiction. (2) The amount of the reduction is the portion of the Parent Entity’s Allocable Share of the Top‑up Tax that is brought into charge by the Intermediate Parent Entity or the Partially‑Owned Parent Entity under a Qualified IIR.