163. Income Inclusion Rule offset mechanism

Terms defined in s 157

• Allocable Share of the Multinational Top-up Tax

  Allocable Share of the Multinational Top-up Tax

  Defined · s 157

  “Allocable Share of the Multinational Top-up Tax” means an amount determined under subsection 162(1);

  Open s 157
• Income Inclusion Rule

  Income Inclusion Rule

  Defined · s 157

  “Income Inclusion Rule” means the rules for the allocation of Multinational Top-up Tax as provided in Chapter 4 of this Part;

  Open s 157
• Intermediate Parent Entity

  Intermediate Parent Entity

  Defined · s 157

  “Intermediate Parent Entity” means a Constituent Entity (other than an Ultimate Parent Entity, Partially-Owned Parent Entity, Permanent Establishment, or Investment Entity) which owns (directly or indirectly) an Ownership Interest in another Constituent Entity in the same Multinational Enterprise Group;

  Open s 157
• Low-Taxed Constituent Entity

  Low-Taxed Constituent Entity

  Defined · s 157

  “Low-Taxed Constituent Entity” means a Constituent Entity of the Multinational Enterprise Group that is located in a Low-Tax Jurisdiction or a Stateless Constituent Entity that, in respect of a Financial Year, has GloBE Income and is subject to an Effective Tax Rate as determined under Chapter 7 of this Part in that Financial Year that is lower than the Minimum Rate;

  Open s 157
• Multinational Top-up Tax

  Multinational Top-up Tax

  Defined · s 157

  “Multinational Top-up Tax” means tax computed for the jurisdiction or Constituent Entity in accordance with sections 175 to 179;

  Open s 157
• Ownership Interest

  Ownership Interest

  Defined · s 157

  “Ownership Interest” means any equity interest that carries rights to the profits, capital or reserves of an Entity, including the profits, capital or reserves of a Main Entity’s Permanent Establishment;

  Open s 157
• Parent Entity

  Parent Entity

  Defined · s 157

  “Parent Entity” means an Ultimate Parent Entity that is not an Excluded Entity, an Intermediate Parent Entity, or a Partially-Owned Parent Entity;

  Open s 157
• Partially-Owned Parent Entity

  Partially-Owned Parent Entity

  Defined · s 157

  “Partially-Owned Parent Entity” means a Constituent Entity other than an Ultimate Parent Entity, Permanent Establishment, Investment Entity or an Insurance Investment Entity that— (a) owns directly or indirectly an Ownership Interest in another Constituent Entity of the same Multinational Enterprise Group; and (b) has more than twenty per cent of the Ownership Interests in its profits held directly or indirectly by persons that are not Constituent Entities of the Multinational Enterprise Group;

  Open s 157
• Qualified Income Inclusion Rule

  Qualified Income Inclusion Rule

  Defined · s 157

  “Qualified Income Inclusion Rule” means a set of rules equivalent to Article 2.1 to Article 2.3 of the GloBE Model Rules including any provisions of the GloBE Model Rules associated with those articles that are included in the domestic law of a jurisdiction and that are implemented and administered in a way that is consistent with the outcomes provided for under the GloBE Model Rules and the GloBE Rules Commentary provided that such jurisdiction does not provide any benefits that are related to such rules;

  Open s 157