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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
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(1) Subsection (2) applies if an election under subsection (3) applies to: (a) a Constituent Entity of an MNE Group; and (b) a Fiscal Year. (2) In computing the Constituent Entity’s GloBE Income or Loss for the Fiscal Year, adjust the Constituent Entity’s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude each qualified debt release amount of the Constituent Entity for the Fiscal Year. Election (3) 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. (4) An election under subsection (3) is an Annual Election.