Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑75 Use of same kind of Qualified Finan8‑75 Use of same kind of Qualified Financial Statements
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8‑75 Use of same kind of Qualified Financial Statements
(1) Subsections (2) and (3) apply if: (a) a Constituent Entity of an MNE Group is a CbCR Resident of a jurisdiction; and (b) an amount in respect of a Fiscal Year is ascertained for the purposes of this Part in relation to the Constituent Entity; and (c) the amount is ascertained by reference to Qualified Financial Statements of the MNE Group to the extent that they relate to the Constituent Entity. (2) Ascertain any other amount that is: (a) in respect of the Fiscal Year; and (b) for the purposes of this Part; and (c) in relation to the Constituent Entity; by reference to the same Qualified Financial Statements. (3) In ascertaining an amount in respect of the Fiscal Year for the purposes of this Part in relation to another Constituent Entity of the MNE Group that is a CbCR Resident of the jurisdiction, the following rules apply: (a) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8‑70(1)(a)—disregard paragraphs 8‑70(1)(b) and (c); (b) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8‑70(1)(b)—disregard paragraphs 8‑70(1)(a) and (c); (c) where the Qualified Financial Statements mentioned in subsection (1) are of a kind mentioned in paragraph 8‑70(1)(c)—disregard paragraphs 8‑70(1)(a) and (b). (4) A reference in this section to Constituent Entity does not include a reference to: (a) a Permanent Establishment; or (b) an NMCE for the Fiscal Year. (5) A reference in this section to an amount does not include a reference to the deferred tax component of income tax expense.