Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑125 Meaning of Qualified Refundable Ta3‑125 Meaning of Qualified Refundable Tax Credit, Non‑Qualified Refundable Tax Credit and Refundable Tax Credit
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3‑125 Meaning of Qualified Refundable Tax Credit, Non‑Qualified Refundable Tax Credit and Refundable Tax Credit
(1) A Refundable Tax Credit is a Qualified Refundable Tax Credit to the extent that it must be paid as cash or available as cash equivalents within 4 years from when a Constituent Entity first satisfies the conditions for receiving the credit under the laws of the jurisdiction granting the credit. (2) However, the Refundable Tax Credit is not a Qualified Refundable Tax Credit: (a) if it is issued under a tax credit regime with a refund mechanism that has no practical significance for those taxpayers that will be entitled to the tax credit; or (b) to the extent that it includes an amount of Tax creditable or refundable under a Qualified Imputation Tax or a Disqualified Refundable Imputation Tax. (3) A Non‑Qualified Refundable Tax Credit is a Refundable Tax Credit that is not a Qualified Refundable Tax Credit or a Marketable Transferable Tax Credit. (4) A tax credit is a Refundable Tax Credit if it is payable in cash or cash equivalents (including by way of discharge against a liability to a Tax which is not a Covered Tax): (a) after it has been used to reduce or discharge any liability to Covered Taxes; or (b) in the absence of any liability for Covered Taxes.