Document ID: chunk:federal_register_of_legislation:C2024A00132:front:0
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Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024

No. 132, 2024

An Act to implement a multinational top‑up tax, and for related purposes

Contents
Part 1—Preliminary
1 Short title
2 Commencement
3 Interpreting this Act
4 Geographical application of this Act
5 Application of this Act to Fiscal Years
Part 2—Liability
Division 1—Australian IIR tax (income inclusion rule tax)
6 Liability to tax—Australian IIR tax
7 Meaning of IIR Top‑up Tax Amount
Division 2—Australian DMT tax (domestic minimum top‑up tax)
8 Liability to tax—Australian DMT tax
9 Meaning of Domestic Top‑up Tax Amount
Division 3—Australian UTPR tax (undertaxed profits rule tax)
10 Liability to tax—Australian UTPR tax
11 Meaning of UTPR Top‑up Tax Amount
Part 3—Core Group and Entity concepts
Division 1—Groups, Entities and Permanent Establishments
12 Meaning of Applicable MNE Group
13 Meanings of Entity and Ultimate Parent Entity
14 Meanings of MNE Group and Group
15 Meaning of Group Entity
16 Meaning of Constituent Entity
17 Groups—general structure
18 Groups—structure with Permanent Establishment
19 Meanings of Permanent Establishment and Main Entity
Division 2—Excluded Entities
20 Meaning of Excluded Entity
21 Meaning of Governmental Entity
22 Meanings of International Organisation and Non‑profit Organisation
23 Meanings of Pension Fund and Pension Services Entity
24 Meanings of Real Estate Investment Vehicle and Investment Fund
25 Meaning of Excluded Service Entity
Division 3—Joint Ventures and Multi‑Parented MNE Groups
26 Joint Ventures
27 Meanings of JV Group and JV Subsidiary
28 Multi‑Parented MNE Groups
Part 4—Rules
29 The Rules—general
30 The Rules—conferral of powers and functions
31 The Rules—incorporation by reference
32 The Rules—retrospective application
33 The Rules—miscellaneous
Part 5—Interpretation
Division 1—Definitions
34 Definitions
35 Currency translation of aggregate variation—definition of Material Competitive Distortion
Division 2—Elections
36 Five‑Year Elections
37 Annual Elections
Division 3—Ownership Interests and Ownership Interest Percentages
38 Meanings of Ownership Interest, Direct Ownership Interest and Indirect Ownership Interest
39 Meanings of Ownership Interest Percentage, Direct Ownership Interest Percentage and Indirect Ownership Interest Percentage
Division 4—Location of Entities and Permanent Establishments
40 Location of an Entity that is not a Flow‑through Entity
41 Location of an Entity that is a Flow‑through Entity
42 Location of a Permanent Establishment
43 Dual‑located entities
44 Change of location during a Fiscal Year

Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024
No. 132, 2024

An Act to implement a multinational top‑up tax, and for related purposes

[Assented to 10 December 2024]

The Parliament of Australia enacts:

Part 1—Preliminary