8‑175 NMCE simplified calculations8‑175 NMCE simplified calculations

8‑175 NMCE simplified calculations

(1) This section applies if: (a) an election under subsection 8‑180(2) applies in relation to a Fiscal Year and a Constituent Entity of an MNE Group; and (b) the Constituent Entity is an NMCE for the Fiscal Year. (2) This section applies for the purpose of working out whether the MNE Group meets the tests mentioned in subsection 8‑155(2) for the Fiscal Year. Simplified income calculation (3) Treat the NMCE’s Total Revenue for a Fiscal Year as its GloBE Income or Loss for the Fiscal Year in the following computations: (a) in computing the MNE Group’s Average GloBE Income or Loss for the jurisdiction for the Fiscal Year as mentioned in paragraph 8‑160(b) (SC De minimis test); (b) in computing the MNE Group’s Effective Tax Rate for the jurisdiction for the Fiscal Year as mentioned in section 8‑165 (SC ETR test); (c) in computing the MNE Group’s Net GloBE Income for the jurisdiction for the Fiscal Year as mentioned in section 8‑170 (SC Routine profits test). Simplified revenue calculation (4) Treat the NMCE’s Total Revenue for a Fiscal Year as its revenue for the Fiscal Year in the following computations: (a) in computing the MNE Group’s GloBE Revenue for a Fiscal Year mentioned in paragraph 5‑110(3)(a); (b) as a result of paragraph (a), in computing the MNE Group’s Average GloBE Revenue for a Fiscal Year as mentioned in paragraph 8‑160(a) (SC De minimis test). Simplified tax calculation (5) Treat the NMCE’s Income Tax Accrued (Current Year) for a Fiscal Year as its Adjusted Covered Taxes for the Fiscal Year in computing the MNE Group’s Effective Tax Rate for the jurisdiction for a Fiscal Year as mentioned in section 8‑165 (SC ETR test).