Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑20 Adjustment—Excluded Dividends3‑20 Adjustment—Excluded Dividends
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3‑20 Adjustment—Excluded Dividends
(1) In computing a Constituent Entity’s GloBE Income or Loss for a Fiscal Year: (a) adjust the Constituent Entity’s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude any Excluded Dividends received or accrued by the Constituent Entity in the Fiscal Year; and (b) if an election under subsection (2) applies to the Constituent Entity and the Fiscal Year—for the purposes of this section and the definition of Excluded Dividends in subsection 3‑25(1), treat a Portfolio Shareholding of the Constituent Entity as a Short‑term Portfolio Shareholding of the Constituent Entity. Election (2) A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to a specified Constituent Entity of the MNE Group. (3) An election under subsection (2) is a Five‑Year Election.