Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
7‑60 Recapture Account Loss Carry‑forwar7‑60 Recapture Account Loss Carry‑forward
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7‑60 Recapture Account Loss Carry‑forward
(1) Subsection (2) applies if: (a) there is a Net GloBE Loss for a Fiscal Year of an MNE Group for a jurisdiction; and (b) at the end of the Fiscal Year, the amount mentioned in paragraph 7‑55(4)(b) (Net GloBE Loss for current year multiplied by Minimum Rate) in respect of that Net GloBE Loss has not been applied fully under subsection 7‑55(4); and (c) there is at least one Deemed Distribution Tax Recapture Account for the jurisdiction for the MNE Group for an earlier Fiscal Year. (2) At the end of the Fiscal Year: (a) a Recapture Account Loss Carry‑forward is established for the Fiscal Year for the jurisdiction for the MNE Group; and (b) the balance of the Recapture Account Loss Carry‑forward is the amount mentioned in paragraph 7‑55(4)(b), to the extent that it has not been so applied. (3) Reduce a Recapture Account Loss Carry‑forward for a Fiscal Year for a jurisdiction for an MNE Group to the extent that it is applied under 7‑55(4)(c).