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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
4‑45 Allocation of amounts from Constitu4‑45 Allocation of amounts from Constituent Entity to Permanent Establishment—general rule
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4‑45 Allocation of amounts from Constituent Entity to Permanent Establishment—general rule
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity of an MNE Group (the Main Entity) to a Permanent Establishment, if the amount is: (a) accrued in the financial accounts of the Main Entity, or of another Constituent Entity, for the Fiscal Year; and (b) so accrued in respect of the GloBE Income or Loss of the Permanent Establishment for the Fiscal Year.