Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
4‑30 Additional Current Top‑up Tax where4‑30 Additional Current Top‑up Tax where MNE Group has no Net GloBE Income and tax falls short of expected tax
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4‑30 Additional Current Top‑up Tax where MNE Group has no Net GloBE Income and tax falls short of expected tax
(1) Subsection (2) applies if: (a) an MNE Group has a Net GloBE Loss for a jurisdiction for a Fiscal Year; and (b) the sum of the Adjusted Covered Taxes for the Fiscal Year of each Constituent Entity of the MNE Group located in the jurisdiction is less than zero; and (c) that sum falls short of the Expected Adjusted Covered Taxes Amount computed under subsection (2). (2) For the purposes of paragraph (1)(c), the Expected Adjusted Covered Taxes Amount is: (a) the Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year; multiplied by: (b) the Minimum Rate. (3) Treat the amount of the shortfall mentioned in paragraph (1)(c) as an amount of Additional Current Top‑up Tax of the MNE Group for the Fiscal Year for the jurisdiction, in respect of that Fiscal Year.