Global Minimum Tax Act, 2024 (Act No. 46 of 2024)

Part IV : Domestic Minimum Top-up Tax

C. Computation of Adjusted Covered Taxes

12. Exclusion of certain foreign taxes on domestic income
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The Adjusted Covered Taxes for each Domestic Constituent Entity, Domestic Joint Venture and Domestic Joint Venture Subsidiary are to be calculated, excluding any tax accrued by a Constituent Entity-owner located in another jurisdiction—

 

(a)with respect to the GloBE Income of a Domestic Constituent Entity, Domestic Joint Venture, and Domestic Joint Venture Subsidiary which would otherwise be allocated to that Domestic Constituent Entity under Article 4.3.2(a), (c) or (d) of the GloBE Model Rules; and

 

(b) that is allocable to a distributing Domestic Constituent Entity, Domestic Joint Venture, and Domestic Joint Venture Subsidiary under Article 4.3.2(e) of the GloBE Model Rules, except that this shall not apply to a withholding tax imposed by the Republic.