Global Minimum Tax Act, 2024 (Act No. 46 of 2024)Part IV : Domestic Minimum Top-up TaxB. Articles that do not apply9. Inapplicable articles in GloBE Model Rules |
| (1) | The following provisions of the GloBE Model Rules shall not apply for the purposes of this Part: |
| (a) | Article 2 (charging provisions); |
| (b) | Article 5.2.4 (allocation of Top-up Tax amongst Constituent Entities); |
| (c) | Article 5.2.5 (allocation of Top-up Tax amongst Constituent Entities when no Net GloBE Income for Fiscal Year); |
| (d) | Article 5.4.2 (allocation of Additional Current Top-up Tax in connection with Article 5.4.1); |
| (e) | Article 5.4.3 (allocation of Additional Current Top-up Tax in relation with Article 4.1.5); |
| (f) | Article 5.4.4 (determination as Low-taxed Constituent Entity); |
| (g) | Article 6.2.1(h) (application of Income Inclusion Rule in respect of acquisition of a target entity); |
| (h) | Article 6.4.1(b) and (c) (application of Income Inclusion Rule and UTPR in connection with Joint Venture and Joint Venture Subsidiaries); |
| (i) | Article 6.5.1(e) and (f) (application of Income Inclusion Rule and UTPR in connection with Multi-Parented MNE Groups); |
| (j) | Article 7.3 (Eligible Distribution Tax System); and |
| (k) | Article 9.3 (exclusion from the UTPR of MNE Groups in the initial phase of their international activity). |