Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p4
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 8957–12309

De minimis exclusion
5‑110 Meaning of Average GloBE Revenue etc.
5‑115 Recalculations under an ETR Adjustment Provision
Part 5‑6—Minority‑Owned Constituent Entities
5‑120 Minority‑Owned Constituent Entities that comprise a Minority‑Owned Subgroup
5‑125 Minority‑Owned Constituent Entities that are not part of a Minority‑Owned Subgroup
5‑130 Meaning of Minority‑Owned Constituent Entity and Minority‑Owned Parent Entity
5‑135 Meaning of Minority‑Owned Subsidiary and Minority‑Owned Subgroup
Chapter 6—Corporate restructurings and holding structures
Part 6‑1—Application of consolidated revenue threshold to Group mergers and demergers
6‑5 Applicable MNE Groups—mergers
6‑10 Applicable MNE Groups—demergers
Part 6‑2—Constituent Entities joining and leaving an MNE Group
Division 1—Transfers of Ownership Interests
6‑15 Application of this Division
6‑20 Target's assets etc. included in MNE Group's Consolidated Financial Statements
6‑25 Target's Financial Accounting Net Income or Loss and Adjusted Covered Taxes
6‑30 Historical carrying value of target's assets and liabilities
6‑35 Target's Eligible Payroll Costs and Tangible Asset Carve‑out Amount
6‑40 Deferred tax assets and deferred tax liabilities
6‑45 Target's Top‑up Tax if Parent Entity in 2 or more MNE Groups
Division 2—Transfer of Ownership Interests treated as transfer of assets and liabilities
6‑50 Transfer of Ownership Interests treated as transfer of assets and liabilities
Part 6‑3—Transfer of assets and liabilities
6‑55 Acquisitions and disposals of assets and liabilities
6‑60 GloBE Reorganisations
6‑65 Meaning of GloBE Reorganisation and Non‑qualifying Gain or Loss
6‑70 Fair value adjustments
Part 6‑4—Joint Ventures
6‑75 Joint Ventures
Part 6‑5—Multi‑Parented MNE Groups
6‑80 Multi‑Parented MNE Groups
6‑85 Meaning of Multi‑Parented MNE Group etc.
Chapter 7—Tax neutrality and distribution regimes
Part 7‑1—Ultimate Parent Entity that is a Flow‑through Entity
7‑5 Flow‑through Entity that is Ultimate Parent Entity—reduce GloBE Income and Covered Taxes
7‑10 Flow‑through Entity that is Ultimate Parent Entity—reduce GloBE Loss
7‑15 Application of sections 7‑5 and 7‑10 to Permanent Establishment
Part 7‑2—Ultimate Parent Entity subject to Deductible Dividend Regime
7‑20 Ultimate Parent Entity subject to Deductible Dividend Regime—reduce GloBE Income and Covered Taxes
7‑25 Ultimate Parent Entity subject to Deductible Dividend Regime—reduce GloBE Income and Covered Taxes of other Constituent Entities
7‑30 Meaning of Deductible Dividend Regime
7‑35 Meaning of Deductible Dividend
Part 7‑3—Eligible Distribution Tax Systems
7‑40 Deemed distribution tax election
7‑45 Meaning of Eligible Distribution Tax System
7‑50 Effect of election—amount in respect of deemed distribution tax added to Adjusted Covered Taxes
7‑55 Deemed Distribution Tax Recapture Account
7‑60 Recapture Account Loss Carry‑forward
7‑65 Effect of positive balance of Deemed Distribution Tax Recapture Account after 4 Fiscal Years—reduce Adjusted Covered Taxes for original year
7‑70 Distribution taxes 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