Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑60 Meeting the Routine profits test8‑60 Meeting the Routine profits test
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8‑60 Meeting the Routine profits test
(1) An MNE Group meets the Routine profits test for a jurisdiction for a Fiscal Year if the MNE Group’s Profit (Loss) before Income Tax for the jurisdiction for the Fiscal Year is equal to or less than the MNE Group’s Substance‑based Income Exclusion Amount for the jurisdiction for the Fiscal Year. (2) For the purposes of subsection (1), in computing the Substance‑based Income Exclusion Amount mentioned in that subsection, treat a Constituent Entity of the MNE Group as being located in the jurisdiction for the Fiscal Year if, and only if: (a) the Constituent Entity is a CbCR Resident of the jurisdiction for the Fiscal Year; and (b) the Constituent Entity is located in the jurisdiction for the Fiscal Year. (3) To avoid doubt, for the purposes of subsection (1), in computing the Substance‑based Income Exclusion Amount mentioned in that subsection, apply the rules in Part 9‑2 (Transitional relief for Substance‑based Income Exclusion).