Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑35 Meaning of Qualified CbC Report8‑35 Meaning of Qualified CbC Report
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8‑35 Meaning of Qualified CbC Report
(1) Qualified CbC Report in relation to a jurisdiction means a Country‑by‑Country Report that is prepared in relation to the jurisdiction, and filed, using Qualified Financial Statements. (2) Subsections (3) and (4) apply if an MNE Group is not required have a Qualified CbC Report in relation to a jurisdiction. (3) For the purposes of this Division, if: (a) the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located has requirements for the filing of Country‑by‑Country Reports; and (b) on the assumption that the MNE Group filed a Country‑by‑Country Report in accordance with those requirements, data from the MNE Group’s Qualified Financial Statements would have been reported as total revenue and profit or loss before tax in that Country‑by‑Country Report; treat that data as being reported in the MNE Group’s Qualified CbC Report. (4) For the purposes of this Division, if: (a) the jurisdiction in which the Ultimate Parent Entity of the MNE Group is located does not have requirements for the filing of Country‑by‑Country Reports; and (b) on the assumption that the MNE Group filed a Country‑by‑Country Report in accordance with the following, data from the MNE Group’s Qualified Financial Statements would have been reported as total revenue and profit or loss before tax in that Country‑by‑Country Report: (i) Transfer Pricing Documentation and Country‑by‑Country Reporting, Action 13 ‑ 2015 Final Report of the OECD/G20 Base Erosion and Profit Shifting Project; (ii) Guidance on the Implementation of Country‑by‑Country Reporting: BEPS Action 13 (Updated May 2024) of the OECD; treat that data as being reported in the MNE Group’s Qualified CbC Report.