Section 3‑210 Adjustment—distributions paid or p - Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 - 3‑210 Adjustment—distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital

3‑210 Adjustment—distributions paid or p3‑210 Adjustment—distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital

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3‑210 Adjustment—distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital

(1) In computing a 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) treat an amount recognised as a decrease to the equity of the Constituent Entity attributable to a distribution paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital issued by the Constituent Entity as an expense; and (b) treat an amount recognised as an increase to the equity of the Constituent Entity attributable to a distribution received or receivable in respect of Additional Tier One Capital or Restricted Tier One Capital held by the Constituent Entity as income. (2) An instrument issued by a Constituent Entity, pursuant to prudential regulatory requirements, that is convertible to equity or written down if a pre‑specified trigger event occurs, and that has other features which are designed to aid loss absorbency in the event of a financial crisis, is: (a) if the requirements are applicable to the banking sector—Additional Tier One Capital; or (b) if the requirements are applicable to the insurance sector—Restricted Tier One Capital.