Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p5
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 12007–15346

excluded in Adjusted Covered Taxes
7‑75 Effect of Constituent Entity leaving jurisdiction, etc.
Part 7‑4—Effective Tax Rate computation for Investment Entities
Division 1—Application
7‑80 Application of this Part
7‑85 Insurance Investment Entity treated as Investment Entity
7‑90 Computing GloBE Income or Loss of Investment Entity
Division 2—Allocable Share of Top‑up Tax of Investment Entity
7‑95 Allocable Share of Top‑up Tax of Investment Entity
Division 3—Top‑up Tax of Investment Entity etc.
7‑100 Top‑up Tax etc. of Investment Entity—primary deeming rule
7‑105 Computing Jurisdictional Top‑up Tax for the purposes of computing Top‑up Tax of Investment Entity
7‑110 Meaning of Allocable GloBE Income or Loss
Division 4—Top‑up Tax of non‑Investment Entity
7‑115 Top‑up Tax of Constituent Entity that is not Investment Entity
Part 7‑5—Investment Entity tax transparency election
7‑120 Application of this Part
7‑125 Investment Entity tax transparency election
7‑130 Effect of election—Investment Entity treated as Tax Transparent Entity
7‑135 Effect of revocation of election—Investment Entity treated as Tax Transparent Entity
Part 7‑6—Taxable distribution method election
7‑140 Application of this Part
7‑145 Taxable distribution method election
7‑150 Effect of election—distributions and deemed distributions received by Constituent Entity‑owner included in computing its GloBE Income, etc.
7‑155 Effect of election—where positive balance of Undistributed Net GloBE Income Account after 3 Fiscal Years, increase Top‑up Tax for tested year
7‑160 Meaning of Undistributed Net GloBE Income Account
7‑165 Deemed distributions
7‑170 Effect of revoking election
Chapter 8—Administration
Part 8‑2—Safe harbours
Division 1—Preliminary
8‑5 Application of this Part to Minority‑Owned Constituent Entities, Joint Ventures and Investment Entities
Division 2—Transitional CbCR Safe Harbour
Subdivision A—Transitional CbCR Safe Harbour
8‑10 Transitional CbCR Safe Harbour—general rule
8‑15 Meaning of Transition Period
Subdivision B—De minimis test
8‑20 Meeting the De minimis test
8‑25 Meaning of Total Revenue of MNE Group
8‑30 Meaning of Profit (Loss) before Income Tax
8‑35 Meaning of Qualified CbC Report
Subdivision C—Simplified ETR test
8‑40 Meeting the Simplified ETR test
8‑45 Meaning of Simplified ETR
8‑50 Meaning of Simplified Covered Taxes
8‑55 Meaning of Transition Rate
Subdivision D—Routine profits test
8‑60 Meeting the Routine profits test
8‑65 Meaning of CbCR Resident
Subdivision E—Qualified Financial Statements
8‑70 Meaning of Qualified Financial Statements
8‑75 Use of same kind of Qualified Financial Statements
Subdivision F—Special rules for particular circumstances
8‑80 Transitional CbCR Safe Harbour—special rule for Joint Ventures
8‑85 Transitional CbCR Safe Harbour—special rule for Ultimate Parent Entity that is Flow‑through Entity
8‑90 Transitional CbCR Safe Harbour—special rule for Deductible Dividend Regimes
8‑95 Transitional CbCR Safe Harbour—special rules for Investment Entities and their Constituent Entity‑owners
8‑100 Transitional CbCR Safe Harbour—special rule for Net Unrealised Fair Value Loss
8‑105 Transitional CbCR Safe Harbour—exclusions
Subdivision G—Treatment of Hybrid Arbitrage Arrangements
8‑110 Transitional CbCR Safe Harbour—Hybrid Arbitrage Arrangements
8‑115 Meaning of Hybrid Arbitrage