Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
7‑110 Meaning of Allocable GloBE Income 7‑110 Meaning of Allocable GloBE Income or Loss
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7‑110 Meaning of Allocable GloBE Income or Loss
(1) An MNE Group’s Allocable GloBE Income or Loss for an Investment Entity for a Fiscal Year is: (a) the Investment Entity’s GloBE Income or Loss for the Fiscal Year; multiplied by: (b) the Inclusion Ratio of the Ultimate Parent Entity of the MNE Group for the Investment Entity for the Fiscal Year.
Note: In computing that Inclusion Ratio, treat the Investment Entities as the only Constituent Entities of the MNE Group (see section 7‑100).
(2) For the purposes of this section, treat the Investment Entity as a Low‑Taxed Constituent Entity. (3) For the purposes of this section: (a) treat references in section 2‑15 to GloBE Income as references to GloBE Income or Loss; and (b) treat the reference in paragraph 2‑15(2)(a) to net income as a reference to net income or loss.