Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p1
Version: federal_register_of_legislation:F2024L01740
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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
I, Dr Jim Chalmers, Treasurer, make the following rules.

Dated    18 December 2024

Dr Jim Chalmers
Treasurer

Contents
Chapter 1—Preliminary etc
Part 1‑1—Preliminary
1‑5 Name
1‑10 Commencement
1‑15 Authority
Part 1‑2—Excluded Entities
1‑20 Excluded Entities
Part 1‑3—Currency conversion
1‑25 Foreign currency translation—general
Chapter 2—Liability amounts
Part 2‑1—Application of the IIR
2‑5 Meaning of IIR Top‑up Tax Amount
Part 2‑2—Allocation of Top‑up Tax under the IIR
2‑10 Meaning of Allocable Share
2‑15 Meaning of Inclusion Ratio
Part 2‑3—IIR offset mechanism
2‑20 IIR offset mechanism
Part 2‑4—Domestic Top‑up Tax Amount
2‑25 Meaning of Domestic Top‑up Tax Amount
2‑30 Amount of Domestic Top‑up Tax Amount
2‑35 Computing Top‑up Tax for the purposes of section 2‑30—principles
2‑40 Domestic Top‑up Tax Amount—special rule for consolidated groups
Part 2‑5—UTPR Top‑up Tax Amount
2‑45 Meaning of UTPR Top‑up Tax Amount
2‑50 UTPR Top‑up Tax Amount—special rule for consolidated groups
2‑55 Meaning of Total UTPR Top‑up Tax Amount
Part 2‑6—Allocation of Top‑Up Tax for the UTPR
2‑60 Allocation of Total UTPR Top‑Up Tax Amount to Australia
2‑65 Meaning of UTPR Percentage
2‑70 Distribution of allocated Total UTPR Top‑Up Tax Amount to Australian Constituent Entity
2‑75 Number of employees in a jurisdiction
2‑80 Meaning of Net Book Value of Tangible Assets
2‑85 Employees and the Net Book Value of Tangible Assets of Investment Entities and Securitisation Entities to be disregarded
2‑90 Employees and the Net Book Value of Tangible Assets allocated to Permanent Establishment
2‑95 Employees and the Net Book Value of Tangible Assets allocated from Flow‑through Entity
Chapter 3—Computation of GloBE Income or Loss
Part 3‑1—Financial accounts
3‑5 Meaning of GloBE Income or Loss
3‑10 Meaning of Financial Accounting Net Income or Loss
Part 3‑2—Adjustments to determine GloBE Income or Loss
Division 1—Article 3.2.1 adjustments
3‑15 Adjustment—net taxes expense
3‑20 Adjustment—Excluded Dividends
3‑25 Meaning of Excluded Dividends, Short‑term Portfolio Shareholding and Portfolio Shareholding
3‑30 Adjustment—Excluded Equity Gain or Loss
3‑35 Meaning of Excluded Equity Gain or Loss
3‑40 Adjustment—insurance reserves
3‑45 Adjustment—Included Revaluation Method Gain or Loss
3‑50 Meaning of Included Revaluation Method Gain or Loss and Other Comprehensive Income
3‑55 Adjustment—asymmetric foreign currency gains or losses
3‑60 Meaning of tax functional currency and accounting functional currency
3‑65 Adjustment—policy disallowed expenses
3‑70 Adjustment—prior period errors and changes in accounting principles
3‑75 Adjustment—accrued pension expense
3‑80 Adjustment—qualified debt release amount
3‑85 Meaning of qualified debt release amount
Division 2—Other Article 3.2 adjustments
3‑90 Adjustment—stock‑based compensation expense
3‑95 Adjustment—Arm's Length Principle and tax/accounting permanent differences in respect of cross‑border transactions
3‑100 Adjustment—Arm's Length Principle and transactions between Constituent Entities located in the same jurisdiction
3‑105 Meaning of Arm's Length Principle
3‑110 Adjustment—Refundable Tax Credits and transferable tax credits
3‑115 Qualified Refundable Tax