Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑245 Adjustment of Permanent Establishm3‑245 Adjustment of Permanent Establishment’s Financial Accounting Net Income or Loss
Start here
Get a plain-English read of 3‑245 Adjustment of Permanent Establishm
Turn the raw legal text into a practical explanation grounded in Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.
3‑245 Adjustment of Permanent Establishment’s Financial Accounting Net Income or Loss
Adjust the amount that would be, disregarding this section, a Permanent Establishment’s Financial Accounting Net Income or Loss to reflect only the amounts of income and expense that are (or, if paragraph (c) applies, would be) attributable to the Permanent Establishment in accordance with: (a) if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(a) of the Act—the Tax Treaty applicable to the Permanent Establishment; or (b) if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(b) of the Act—the law of the jurisdiction in which the Permanent Establishment is located; or (c) if the Permanent Establishment is a Permanent Establishment because of paragraph 19(1)(c) of the Act—Article 7 of the OECD Model Tax Convention.