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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
4‑70 Amounts accrued in financial accoun4‑70 Amounts accrued in financial accounts of Constituent Entity‑owner on distribution from Constituent Entity to Constituent Entity‑owner—allocation to Constituent Entity
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4‑70 Amounts accrued in financial accounts of Constituent Entity‑owner on distribution from Constituent Entity to Constituent Entity‑owner—allocation to Constituent Entity
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity‑owner of a Constituent Entity to the Constituent Entity if the amount is: (a) accrued in the financial accounts of the Constituent Entity‑owner for the Fiscal Year; and (b) so accrued in respect of distributions or deemed distributions during the Fiscal Year from the Constituent Entity to the Constituent Entity‑owner that arise from the direct Ownership Interests that it holds in the Constituent Entity.