Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
4‑115 Meaning of Disallowed Accrual and 4‑115 Meaning of Disallowed Accrual and Unclaimed Accrual
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4‑115 Meaning of Disallowed Accrual and Unclaimed Accrual
(1) A Disallowed Accrual, of a Constituent Entity of an MNE Group for a Fiscal Year, means a movement in deferred tax expense accrued in the financial accounts of the Constituent Entity for the Fiscal Year that relates to: (a) an uncertain tax position; or (b) distributions from any Constituent Entity of the MNE Group (whether or not the Constituent Entity mentioned previously in this subsection). (2) An Unclaimed Accrual, of a Constituent Entity of an MNE Group for a Fiscal Year, means an increase in a deferred tax liability recorded in the financial accounts of the Constituent Entity for the Fiscal Year (the current year) if: (a) it is not expected to be reversed by the end of the fifth following Fiscal Year; and (b) an election under subsection (3) applies to the Constituent Entity for the current 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. (4) An election under subsection (3) is an Annual Election.