Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑225 Transitional UTPR Safe Harbour8‑225 Transitional UTPR Safe Harbour
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8‑225 Transitional UTPR Safe Harbour
(1) Subsection (2) applies if an election for an MNE Group under subsection (3) applies to a Fiscal Year and the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located (the UPE jurisdiction). (2) In computing the Total UTPR Top‑up Tax Amount for the MNE Group for the Fiscal Year, treat the following as being zero: (a) the Top‑up Tax for the Fiscal Year of each Low‑Taxed Constituent Entity for the Fiscal Year of the MNE Group that is located in the UPE jurisdiction; (b) if there are one or more Joint Ventures of the MNE Group—the Ultimate Parent Entity’s Allocable Share of the Top‑up Tax of each Joint Venture, and of each of its JV Subsidiaries (if any), that is located in the UPE jurisdiction. Election (3) A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to the Fiscal Year and the UPE jurisdiction if: (a) the Fiscal Year: (i) does not exceed 12 months; and (ii) starts on or before 31 December 2025; and (iii) ends before 31 December 2026; and (b) the UPE jurisdiction has a corporate income tax that applies at a rate of at least 20%. (4) An election under subsection (3) is an Annual Election.
Chapter 9—Transition rules