Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑25 Meaning of Total Revenue of MNE Gro8‑25 Meaning of Total Revenue of MNE Group
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8‑25 Meaning of Total Revenue of MNE Group
(1) An MNE Group’s Total Revenue, for a jurisdiction for a Fiscal Year, means the MNE Group’s total revenues in the jurisdiction, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year. (2) Subsection (3) applies if an intragroup payment that is made between Group Entities of the MNE Group: (a) is treated as income in the Qualified Financial Statements of the recipient Group Entity; and (b) is treated as expense in the Qualified Financial Statements of the paying Group Entity. (3) For the purposes of subsection (1), include the amount of the intragroup payment in the MNE Group’s total revenues mentioned in that subsection.