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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
In force
Administered by
Department of the Treasury
This item is authorised by the following title:
Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024
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F2024L01740
23 December 2024
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EXPLANATORY STATEMENT
Glossary
Scope of entities
Liability to Top up Tax
GloBE Income or Loss
Adjusted Covered Taxes
Computing Top up Tax
Corporate structures
Investment Entities
Safe
Transitional provisions
Definitions
Statement of Compatibility with Human Rights
Collapse
Conversion tables
Outline of chapter
Detailed explanation of new law
Scope: Excluded entities
Outline of chapter
Detailed explanation of new law
Top-up tax arising under the IIR
Top-up Tax arising under the DMT
Top up Tax arising under the UTPR
Table of Contents:
Outline of Chapter
Detailed explanation of new law
Financial accounts
Adjustments to determine GloBE Income or Loss
Inclusions
Exclusions
Elections
Allocating income between entities
Outline of chapter
Detailed explanation of new law
Adjusted Covered Taxes
Allocation of Covered Taxes
Mechanism to address temporary differences
Total Deferred Tax Adjustment Amount
Post-filing adjustments and tax rate changes
Outline of chapter
Detailed explanation of new law
Determination of effective tax rate
Top up Tax
Substance-based Income Exclusion
Additional Current Top-up Tax
De minimis exclusion
Minority-Owned Constituent Entities
Outline of chapter
Detailed explanation of new law
Mergers and demergers
Transfers of Ownership Interests
Transfer of Ownership Interests treated as transfer of assets and liabilities
Transfer of assets and liabilities
Joint Ventures
Multi-Parented MNE Groups
Outline of chapter
Detailed explanation of new law
UPE that is a Flow-through Entity
UPE subject to Deductible Dividend Regime
Eligible Distribution Tax Systems
ETR computation for Investment Entities
Investment Entity tax transparency election
Taxable distribution method election
Outline of chapter
Detailed explanation of new law
Transitional CbC Reporting Safe Harbour
Permanent Safe Harbour: simplified calculations
QDMTT Safe Harbour
UTPR Safe Harbour
Outline of chapter
Detailed explanation of new law
Tax attributes upon transition
Transitional relief for the Substance-based Income Exclusion
Transitional Exclusion from the UTPR for an MNE Group in the initial phase of activity
Outline of chapter
Detailed explanation of new law
Overview of Legislative Instrument
Human rights implications
Conclusion