Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑140 Meaning of Non‑Marketable Transfer3‑140 Meaning of Non‑Marketable Transferable Tax Credit and Other Tax Credit
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3‑140 Meaning of Non‑Marketable Transferable Tax Credit and Other Tax Credit
(1) A Non‑Marketable Transferable Tax Credit is: (a) a tax credit that: (i) is held by the person to whom the tax credit was originally granted; and (ii) is transferable; and (iii) is not a Marketable Transferable Tax Credit; or (b) a tax credit that: (i) is held by a purchaser; and (ii) is not a Marketable Transferable Tax Credit. (2) However, for the purposes of this instrument, treat a tax credit as not being a Non‑Marketable Transferable Tax Credit to the extent that it is also Qualified Refundable Tax Credit. (3) A tax credit is an Other Tax Credit to the extent that it is not any of the following: (a) a Qualified Refundable Tax Credit; (b) a Marketable Transferable Tax Credit; (c) a Non‑Marketable Transferable Tax Credit.