Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p54
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 136253–138953

Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year;
 (c) if the Constituent Entity transferred a Non‑Marketable Transferable Tax Credit during the Fiscal Year:
 (i) where the Constituent Entity is the person to whom the tax credit was originally granted—the amount (if any) received by the Constituent Entity in exchange for the transfer; or
 (ii) where subparagraph (i) does not apply, and the transfer amount mentioned in subsection 3‑145(3) is a positive number—that amount;
Note: If the transfer amount is a negative number, it is included in the Constituent Entity's GloBE Income or Loss: see subsection 3‑145(2).
 (d) the amount (if any) of Covered Taxes refunded or credited to the Constituent Entity (other than a Qualified Refundable Tax Credit or a Marketable Transferable Tax Credit) that is not treated as an adjustment to the Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year;
 (e) the amount (if any) of the Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year that relates to an uncertain tax position;
 (f) the amount (if any) of the Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year that is not expected to be paid within 3 years after the last day of the Fiscal Year.

Use of purchased Non‑Marketable Transferable Tax Credits
 (2) Subsection (3) applies if an amount mentioned in paragraph (1)(b) is in respect of a tax credit that is a Non‑Marketable Transferable Tax Credit purchased by the Constituent Entity.
 (3) Reduce the amount by the multiplying it by the following fraction:
 (a) the excess of the face value of the tax credit over its purchase price;
divided by:
 (b) face value of the tax credit.

4‑25  No double counting of Covered Taxes
  For the purposes of this Chapter, do not take account of an amount of Covered Taxes more than once in computing the Adjusted Covered Taxes of:
 (a) a Constituent Entity for a particular Fiscal Year or another Fiscal Year; or
 (b) multiple Constituent Entities for a particular Fiscal Year or another Fiscal Year.

4‑30  Additional Current Top‑up Tax where MNE Group has no Net GloBE Income and tax falls short of expected tax
 (1) Subsection (2) applies if:
 (a) an MNE Group has a Net GloBE Loss for a jurisdiction for a Fiscal Year; and
 (b) the sum of the Adjusted Covered Taxes for the Fiscal Year of each Constituent Entity of the MNE Group located in the jurisdiction is less than zero; and
 (c) that sum falls short of the Expected Adjusted Covered Taxes Amount computed under subsection (2).
 (2) For the purposes of paragraph (1)(c), the Expected Adjusted Covered Taxes Amount is:
 (a) the Net GloBE Loss of the MNE