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

Part IV : Domestic Minimum Top-up Tax

E. Transition Rules

18. Later Transition Year

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(1) This paragraph applies when the Transition Year under section 17 was the first Fiscal Year in which the MNE Group became subject to this Act, and Domestic Constituent Entities were not subject to a Qualified IIR in that Fiscal Year.

 

(2) Where one or more Domestic Constituent Entities, Domestic Joint Ventures and Domestic Joint Venture Subsidiaries become subject to a Qualified IIR for a subsequent Fiscal Year in another jurisdiction, the transition year for the Republic shall be revised to the Fiscal Year in which a Domestic Constituent Entity first became subject to a Qualified IIR for that, and all subsequent, Fiscal Years.