Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
5‑30 Meaning of Jurisdictional Top‑up Ta5‑30 Meaning of Jurisdictional Top‑up Tax
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5‑30 Meaning of Jurisdictional Top‑up Tax
The Jurisdictional Top‑up Tax of an MNE Group for a jurisdiction for a Fiscal Year is the amount computed in accordance with the following formula (but not less than zero): Start formula open bracket Top-up Tax Percentage times Excess Profit close bracket plus Additional Current Top-up Tax minus Domestic Top-up Tax end formula where:
Additional Current Top‑up Tax is the sum of the amounts determined or treated as Additional Current Top‑up Tax of the MNE Group for the jurisdiction for the Fiscal Year.
Domestic Top‑up Tax is the sum of the amounts payable by each Constituent Entity of the MNE Group under a Qualified Domestic Minimum Top‑up Tax of the jurisdiction for the Fiscal Year.
Excess Profit is the Excess Profit of the MNE Group for the jurisdiction for the Fiscal Year.
Top‑up Tax Percentage is the Top‑up Tax Percentage of the MNE Group for the jurisdiction for the Fiscal Year.