Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
6‑35 Target’s Eligible Payroll Costs and6‑35 Target’s Eligible Payroll Costs and Tangible Asset Carve‑out Amount
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6‑35 Target’s Eligible Payroll Costs and Tangible Asset Carve‑out Amount
(1) For the purposes of this instrument, in computing the target’s Eligible Payroll Costs for the transfer year, take into account only those costs reflected in: (a) in applying this instrument in relation to the disposing MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group for the transfer year; or (b) in applying this instrument in relation to the acquiring MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group for the transfer year. (2) For the purposes of this instrument, in computing the Tangible Asset Carve‑out Amount for the target for the transfer year, adjust the carrying value of the target’s Eligible Tangible Assets for the transfer year proportionally to correspond with the period in the transfer year in which that the target was a Group Entity of: (a) in applying this instrument in relation to the disposing MNE Group—the disposing MNE Group; or (b) in applying this instrument in relation to the acquiring MNE Group—the acquiring MNE Group.