Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
7‑170 Effect of revoking election7‑170 Effect of revoking election
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7‑170 Effect of revoking election
(1) This section applies if: (a) an election under subsection 7‑145(1) applies to: (i) an Investment Entity that is a Constituent Entity of an MNE Group; and (ii) a Constituent Entity‑owner of the Investment Entity; and (b) the election is revoked in a Fiscal Year (the revocation year); and (c) there is an Undistributed Net GloBE Income Account for the Investment Entity for the Fiscal Year that is the second Fiscal Year preceding the revocation year; and (d) the balance of the Undistributed Net GloBE Income Account is above zero at the end of the revocation year. (2) In computing the Investment Entity’s GloBE Income or Loss for the revocation year, include the Constituent Entity‑owner’s proportionate share of the balance of the Undistributed Net GloBE Income Account (the Constituent Entity‑owner’s undistributed share). (3) For purposes of Chapter 2: (a) treat the Investment Entity as a Low‑Taxed Constituent Entity of the MNE Group for the reporting year; and (b) treat the Top‑up Tax of the Investment Entity for the reporting year as being the amount equal to: (i) the Constituent Entity‑owner’s undistributed share; multiplied by: (ii) the Minimum Rate.
Chapter 8—Administration