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

Part III : Income Inclusion Rule

5. Inapplicable articles in GloBE Model Rules

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The following provisions of the GloBE Model Rules shall not apply for the purposes of this Part:

 

(a) Articles 2.4 to 2.6 (UTPR charging provisions); and

 

(b) Article 9.3 (exclusion from the UTPR of MNE Groups in the initial phase of their international activity).