Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑205 Adjustment—insurance company amoun3‑205 Adjustment—insurance company amounts charged to policyholders for taxes paid in respect of returns to policy holders
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3‑205 Adjustment—insurance company amounts charged to policyholders for taxes paid in respect of returns to policy holders
(1) Subsection (2) applies if a Constituent Entity of an MNE Group is an insurance company. (2) In computing the Constituent Entity’s GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity’s Financial Accounting Net Income or Loss for the Fiscal Year so as to: (a) exclude any amount that is charged to policyholders for Taxes paid by the Constituent Entity in respect of returns to the policyholders; and (b) include returns to policyholders that are not reflected in the Constituent Entity’s Financial Accounting Net Income or Loss for the Fiscal Year, to the extent that a corresponding increase or decrease in liability to policyholders is reflected in its Financial Accounting Net Income or Loss for that Fiscal Year.