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Finance (No. 2) Act 2023 · Updated to 29 Dec 2023 · Chapter 5

165. Adjustments to determine GloBE Income or Loss

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(1)

A Constituent Entity’s Financial Accounting Net

Income or Loss is adjusted for the following items to arrive at that Entity’s GloBE Income or Loss:

(a)

Net Taxes Expense;

(b)

Excluded Dividends;

(c)

Excluded Equity Gain or Loss;

(d)

Included Revaluation Method Gain or Loss;

(e)

Gain or loss from disposition of assets and liabilities excluded under section 186;

(f)

Asymmetric Foreign Currency Gains or Losses;

(g)

Policy Disallowed Expenses;

(h)

Prior Period Errors and Changes in Accounting

Principles; and

(i)

Accrued Pension Expense.

(2)

At the election of the Filing Constituent Entity, a Constituent Entity may substitute the amount allowed as a deduction in the computation of its taxable income in its location for the amount expensed in its financial accounts for a cost or expense of such Constituent Entity that was paid with stock-based compensation.

(3)

If the stock-based compensation expense arises in connection with an option that expires without exercise, the Constituent Entity shall include the total amount previously deducted in the computation of its GloBE Income or Loss for the Financial Year in which the option expires.

(4)

The election in subsection (2) is a Five-Year Election and shall be applied consistently to the stock-based compensation of all Constituent Entities located in the same jurisdiction for the year in which the election is made and all subsequent

Financial Years.

Finance (No. 2)

(5)

If the election is made in a Financial Year after some of the stock-based compensation of a transaction has been recorded in the financial accounts, the Constituent Entity shall include in the computation of its GloBE Income or

Loss for that Financial Year an amount equal to the excess of the cumulative amount allowed as an expense in the computation of its GloBE Income or Loss in previous Financial Years over the cumulative amount that would have been allowed as an expense if the election had been in place in those

Financial Years.

(6)

If the election is revoked, the Constituent Entity shall include in the computation of its GloBE Income or Loss for the revocation year the amount deducted pursuant to the election that exceeds financial accounting expense accrued in respect of the stock-based compensation that has not been paid.

(7)

Any transaction between Constituent Entities located in different jurisdictions that is not recorded in the same amount in the financial accounts of both Constituent Entities or that is not consistent with the Arm’s Length Principle shall be adjusted so as to be in the same amount and consistent with the Arm’s Length Principle.

(8)

A loss from a sale or other transfer of an asset between two Constituent Entities located in the same jurisdiction that is not recorded consistent with the Arm’s Length Principle shall be recomputed based on the Arm’s Length Principle if that loss is included in the computation of GloBE Income or Loss.

(9)

Rules for allocating income or loss between a Main

Entity and its Permanent Establishments are as provided in section 167.

(10)

Qualified Refundable Tax Credits shall be treated as income in the computation of GloBE Income or Loss of a Constituent Entity.

(11)

Non-Qualified Refundable Tax Credits shall not be treated as income in the computation of GloBE Income or Loss of a Constituent Entity.

(12)

With respect to assets and liabilities that are subject to fair value or impairment accounting in the Consolidated

Financial Statements, a Filing Constituent Entity may elect to determine gains and losses using the realisation principle for the purpose of computing GloBE Income.

(13)

The election in subsection (12) is a Five-Year Election and applies to—

(a)

all Constituent Entities located in the jurisdiction to which the election applies; and

(b)

all assets and liabilities of such Constituent Entities, unless the Filing Constituent Entity chooses to limit the election to tangible assets of such Constituent

Entities or to Constituent Entities that are Investment

Entities.

(14)

For the purposes of an election under subsection (12)—

(a)

all gains or losses attributable to fair value or impairment accounting with respect to an asset or liability shall be excluded from the computation of GloBE Income or Loss;

(b)

the carrying value of an asset or liability for the purpose of determining gain or loss shall be its carrying value adjusted for accumulated depreciation at the later of—

(i)

the first day of the election year; or

(ii)

the date the asset was acquired or liability was incurred.

(15)

If the election under subsection (12) is revoked, the GloBE Income or Loss of the Constituent Entities is adjusted by the difference at the beginning of the revocation year between the fair value of the asset or liability and the carrying value of the asset or liability determined pursuant to the election adjusted for accumulated depreciation.

Finance (No. 2)

(16)

Where there is Aggregate Asset Gain in a jurisdiction in a Financial Year, the Filing Constituent Entity may make, under this subsection, an Annual Election for that jurisdiction to adjust GloBE Income or Loss with respect to each previous

Financial Year in the Look-back Period in the manner described in paragraphs (18)(b) and (c) and shall spread any remaining Adjusted Asset Gain over the Look-back Period in the manner described in paragraphs (18)(d) and (e).

(17)

For the purposes of subsection (16) the Effective Tax

Rate and Multinational Top-up Tax, if any, for any previous

Financial Year must be re-calculated under subsection 181(1).

(18)

When an election is made under subsection (16)—

(a)

Covered Taxes with respect to any Net Asset Gain or Net Asset Loss in the Election Year shall be excluded from the computation of Adjusted Covered Taxes;

(b)

the Aggregate Asset Gain in the Election Year shall be carried-back to the earliest Loss Year and set-off rateably against any Net Asset Loss of any

Constituent Entity located in that jurisdiction;

(c)

if, for any Loss Year, the Adjusted Asset Gain exceeds the total amount of Net Asset Loss of all Constituent

Entities located in that jurisdiction, the Adjusted

Asset Gain shall be carried forward to the following

Loss Year, if any, and applied rateably against any

Net Asset Loss of any Constituent Entity located in that jurisdiction;

(d)

any Adjusted Asset Gain that remains after the application of paragraphs (b) and (c) shall be allocated evenly to each Financial Year in the Look-back Period;

(e)

the Allocated Asset Gain for the relevant year shall be included in the computation of GloBE

Income or Loss for a Constituent Entity located in that jurisdiction in that year in accordance with the following formula:

A x B

C where

A is the Allocated Asset Gain for the relevant year;

B is the specified Constituent

Entity’s Net Asset Gain in the

Election Year; and

C is the Net Asset Gain of all specified Constituent Entities in the Election Year.

(19)

If there is no specified Constituent Entity for a relevant year the Adjusted Asset Gain allocated to that year will be allocated equally to each Constituent Entity in the jurisdiction in that year.

(20)

The computation of a Low-Tax Entity’s GloBE Income or Loss shall exclude any expense attributable to an Intragroup

Financing Arrangement that can reasonably be anticipated, over the expected duration of the arrangement to increase the amount of expenses taken into account in calculating the GloBE Income or Loss of the Low-Tax Entity without resulting in a commensurate increase in the taxable income of the High-Tax Counterparty.

(21)

An Ultimate Parent Entity may elect to apply its consolidated accounting treatment to eliminate income, expense, gains, and losses from transactions between Constituent

Entities that are located, and included in a tax consolidation group, in the same jurisdiction for the purpose of computing each such Constituent Entity’s Net GloBE Income or Loss.

Finance (No. 2)

(22)

The election under subsection (21) is a Five-Year

Election and upon making or revoking such election, appropriate adjustments shall be made for the purposes of the GloBE Rules such that there shall not be duplications or omissions of items of GloBE Income or Loss as a result of having made or revoked the election.

(23)

An insurance company shall—

(a)

exclude from the computation of GloBE Income or

Loss amounts charged to policy holders for Taxes paid by the insurance company in respect of returns to the policy holders; and

(b)

include in the computation of GloBE Income or Loss any returns to policy holders that are not reflected in Financial Accounting Net Income or Loss to the extent the corresponding increase or decrease in liability to the policy holders is reflected in its

Financial Accounting Net Income or Loss.

(24)

Amounts recognised as—

(a)

a decrease to the equity of a Constituent Entity attributable to distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier

One Capital issued by the Constituent Entity shall be treated as an expense in the computation of its

GloBE Income or Loss; and

(b)

an increase to the equity of a Constituent Entity attributable to distributions received or receivable in respect of Additional Tier One Capital or Restricted

Tier One Capital held by the Constituent Entity shall be included in the computation of its GloBE

Income or Loss.

(25)

A Constituent Entity’s Financial Accounting Net

Income or Loss must be adjusted as necessary to reflect the requirements of the relevant provisions of Chapters 8 and 9

of this Part.

(26)

For the purposes of this section—

“accounting functional currency” means the functional currency used to determine the Constituent Entity’s Financial

Accounting Net Income or Loss;

“Accrued Pension Expense” means the difference between the amount of pension liability expense included in the

Financial Accounting Net Income or Loss and the amount contributed to a Pension Fund for the Financial Year;

“Additional Tier One Capital” means an instrument issued by a Constituent Entity pursuant to prudential regulatory requirements applicable to the banking sector that is convertible to equity or written down if a pre-specified trigger event occurs and that has other features which are designed to aid loss absorbency in the event of a financial crisis;

“Allocated Asset Gain” means the Adjusted Asset Gain that is allocated to a Financial Year in the Look-back Period, for the relevant year;

“Arm’s Length Principle” means the principle under which transactions between Constituent Entities must be recorded by reference to the conditions that would have been obtained between independent enterprises in comparable transactions and under comparable circumstances;

“Asymmetric Foreign Currency Gains or Losses” means foreign currency gains or losses of an entity whose accounting and tax functional currencies are different and that are—

(a)

included in the computation of a Constituent Entity’s taxable income or loss and attributable to fluctuations in the exchange rate between its accounting functional currency and its tax functional currency;

(b)

included in the computation of a Constituent Entity’s

Financial Accounting Net Income or Loss and attributable to fluctuations in the exchange rate between its tax functional currency and its accounting functional currency;

Finance (No. 2)

(c)

included in the computation of a Constituent Entity’s

Financial Accounting Net Income or Loss and attributable to fluctuations in the exchange rate between a third foreign currency and its accounting functional currency; and

(d)

attributable to fluctuations in the exchange rate between a third foreign currency and its tax functional currency, whether or not such foreign currency gain or loss is included in taxable income;

“Included Revaluation Method Gain or Loss” means the net gain or loss, increased or decreased by any associated

Covered Taxes, for the Financial Year in respect of all property, plant and equipment that arises under an accounting method or practice that—

(a)

periodically adjusts the carrying value of such property to its fair value;

(b)

records the changes in value in Other Comprehensive

Income; and

(c)

does not subsequently report the gains or losses recorded in Other Comprehensive Income through profit and loss;

“Low-Tax Entity” means a Constituent Entity located in a Low-Tax Jurisdiction or a jurisdiction that would be a Low-Tax Jurisdiction if the Effective Tax Rate for the jurisdiction were determined without regard to any income or expense accrued by that Entity in respect of an Intragroup

Financing Arrangement;

“Net Taxes Expense” means the net amount of—

(a)

any Covered Taxes accrued as an expense and any current and deferred Covered Taxes included in the income tax expense, including Covered Taxes on income that is excluded from the GloBE Income or Loss computation;

(b)

any deferred tax asset attributable to a loss for the

Financial Year;

(c)

any Qualified Domestic Top-up Tax accrued as an expense;

(d)

any taxes arising pursuant to this Part accrued as an expense;

(e)

any Disqualified Refundable Imputation Tax accrued as an expense; and

(f)

taxes accrued by an insurance company in respect of returns to policyholders to the extent that subsection (23) applies in relation to those taxes;

“Policy Disallowed Expenses” means—

(a)

expenses accrued by the Constituent Entity for illegal payments, including bribes and kickbacks; and

(b)

expenses accrued by the Constituent Entity for fines and penalties that equal or exceed fifty thousand euro or an equivalent in the functional currency in which the Constituent Entity’s Financial Accounting

Net Income or Loss was calculated;

“Prior Period Errors and Changes in Accounting Principles”

means all changes in the opening equity at the beginning of the Financial Year of a Constituent Entity attributable to—

(a)

a correction of an error in the determination of

Financial Accounting Net Income in a previous

Financial Year that affected the income or expenses includible in the computation of GloBE Income or

Loss for such Financial Year, except to the extent such error correction resulted in a material decrease to a liability for Covered Taxes subject to section 173;

(b)

a change in accounting principle or policy that affects income or expenses includible in the computation of GloBE Income or Loss;

Finance (No. 2)

“Restricted Tier One Capital” means an instrument issued by a Constituent Entity pursuant to prudential regulatory requirements applicable to the insurance sector that is convertible to equity or written down if a pre-specified trigger event occurs and that has other features which are designed to aid loss absorbency in the event of a financial crisis;

“specified Constituent Entity” means a Constituent Entity that has Net Asset Gain in the Election Year and was located in the jurisdiction in the relevant year;

“tax functional currency” means the functional currency used to determine the Constituent Entity’s taxable income or loss for a Covered Tax in the jurisdiction in which it is located;

“third foreign currency” means a currency that is not the

Constituent Entity’s tax functional currency or accounting functional currency.

Terms defined in s 157

Adjusted Asset Gain
Defined · s 157
“Adjusted Asset Gain” means, in respect of Aggregate Asset Gain that is subject to an election under subsections 165(16) to (19), an amount equal to the Aggregate Asset Gain in the Election Year, reduced by any amount of such gain that has been applied against the Net Asset Loss in a prior Loss Year under paragraph 165(18)(b) or (c);
Open s 157
Adjusted Covered Taxes
Defined · s 157
“Adjusted Covered Taxes” means an amount as determined under section 169;
Open s 157
Aggregate Asset Gain
Defined · s 157
“Aggregate Asset Gain” means, in respect of an election under subsection 165(16), the net gain in the Election Year from the disposition of Local Tangible Assets by all Constituent Entities located in the jurisdiction excluding the gain or loss on a transfer of assets between Group Members;
Open s 157
Annual Election
Defined · s 157
“Annual Election” means an election in the prescribed form made by a Filing Constituent Entity and furnished to the Director General and that applies only for the Financial Year for which the election is made;
Open s 157
Constituent Entity
Defined · s 157
“Constituent Entity” means— (a) any Entity that is included in a Group; or (b) any Permanent Establishment of a Main Entity that is within paragraph (a) and which is treated as separate from the Main Entity and any other Permanent Establishment of that Main Entity, but does not include an Excluded Entity;
Open s 157
Covered Taxes
Defined · s 157
“Covered Taxes” means— (a) taxes recorded in the financial accounts of a Constituent Entity with respect to its income or profits or its share of the income or profits of a Constituent Entity in which it owns an Ownership Interest; (b) taxes on distributed profits, deemed profit distributions, and non-business expenses imposed under an Eligible Distribution Tax System; (c) taxes imposed in lieu of a generally applicable corporate income tax; and (d) taxes levied by reference to retained earnings and corporate equity, including a Tax on multiple components based on income and equity, Finance (No. 2) but does not include any amount of— (a) Multinational Top-up Tax accrued by a Parent Entity under a Qualified Income Inclusion Rule; (b) Qualified Domestic Top-up Tax accrued by a Constituent Entity; (c) taxes attributable to an adjustment made by a Constituent Entity as a result of the application of a set of rules equivalent to Articles 2.4 to 2.6 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 provided that such jurisdiction does not provide any benefits that are related to such rules; (d) a Disqualified Refundable Imputation Tax; (e) taxes paid by an insurance company in respect of returns to policy holders;
Open s 157
Disqualified Refundable Imputation Tax
Defined · s 157
“Disqualified Refundable Imputation Tax” means any amount of Tax, other than a Qualified Imputation Tax, accrued or paid by a Constituent Entity that is— (a) refundable to the beneficial owner of a dividend distributed by such Constituent Entity in respect of that dividend or creditable by the beneficial owner against a tax liability other than a tax liability in respect of such dividend; or (b) refundable to the distributing corporation upon distribution of a dividend;
Open s 157
Effective Tax Rate
Defined · s 157
“Effective Tax Rate” means, in respect of a Multinational Enterprise Group, the sum of the Adjusted Covered Taxes of each Constituent Entity located in the jurisdiction divided by the Net GloBE Income of the jurisdiction for the Financial Year;
Open s 157
Election Year
Defined · s 157
“Election Year” means, in respect of an Annual Election, the year for which the election is made;
Open s 157
Entity
Defined · s 157
“Entity” means— (a) any legal person (other than a natural person); or (b) an arrangement that prepares separate financial accounts, such as a partnership or trust;
Open s 157
Excluded Dividends
Defined · s 157
“Excluded Dividends” means dividends or other distributions received or accrued in respect of an Ownership Interest, except for— (a) a Short-term Portfolio Shareholding; and (b) an Ownership Interest in an Investment Entity that is subject to an election under section 194;
Open s 157
Excluded Equity Gain or Loss
Defined · s 157
“Excluded Equity Gain or Loss” means the gain, profit or loss included in the Financial Accounting Net Income or Loss of the Constituent Entity arising from— (a) gains and losses from changes in fair value of an Ownership Interest, except for a Portfolio Shareholding; (b) profit or loss in respect of an Ownership Interest included under the equity method of accounting; and (c) gains and losses from disposition of an Ownership Interest, except for a disposition of a Portfolio Shareholding;
Open s 157
Filing Constituent Entity
Defined · s 157
“Filing Constituent Entity” means an Entity filing the return in accordance with section 201 or 202;
Open s 157
Financial Accounting Net Income or Loss
Defined · s 157
“Financial Accounting Net Income or Loss” means the net income or loss determined for a Constituent Entity before any consolidation adjustments eliminating intra-group transactions in preparing Consolidated Financial Statements of the Ultimate Parent Entity;
Open s 157
Financial Year
Defined · s 157
“Financial Year” means an accounting period with respect to which the Ultimate Parent Entity of the Multinational Enterprise Group prepares its Consolidated Financial Statements and in the case of Consolidated Financial Statements as defined in paragraph (d) of the definition of “Consolidated Financial Statements”, Financial Year means the calendar year;
Open s 157
Five-Year Election
Defined · s 157
“Five-Year Election” means an election in the prescribed form made by a Filing Constituent Entity and furnished to the Director General with respect to a Financial Year (hereinafter referred to as the “election year”) that cannot be revoked with respect to the election year or the four succeeding Financial Years and if revoked with respect to a Financial Year (hereinafter referred to as the “revocation year”), a new election cannot be made with respect to the four Financial Years succeeding the revocation year;
Open s 157
GloBE Income or Loss
Defined · s 157
“GloBE Income or Loss” means the Financial Accounting Net Income or Loss determined for the Constituent Entity for the Financial Year adjusted for the items described in sections 165 to 168 of each Constituent Entity;
Open s 157
GloBE Rules
Defined · s 157
“GloBE Rules” means— (a) the GloBE Model Rules; (b) the GloBE Rules Commentary and any further commentaries published by the Organisation for Economic Co-operation and Development/G20 Inclusive Framework on Base Erosion and Profit Shifting that are relevant to the implementation of the GloBE Rules; and (c) any Agreed Administrative Guidance or any other guidance published by the Organisation for Economic Co-operation and Development/G20 Inclusive Framework on Base Erosion and Profit Shifting that are relevant to the implementation of the GloBE Rules;
Open s 157
Group
Defined · s 157
“Group” means— (a) a collection of Entities that are related through ownership or control such that the assets, liabilities, income, expenses and cash flows of those Entities are— (i) included in the Consolidated Financial Statements of the Ultimate Parent Entity; or Finance (No. 2) (ii) excluded from the Consolidated Financial Statements of the Ultimate Parent Entity solely on size or materiality grounds, or on the grounds that the Entity is held for sale; or (b) an Entity that is located in one jurisdiction and has one or more Permanent Establishments located in other jurisdictions provided that the Entity is not a part of another Group mentioned in paragraph (a);
Open s 157
High-Tax Counterparty
Defined · s 157
“High-Tax Counterparty” means a Constituent Entity that is located in a jurisdiction that is not a Low-Tax Jurisdiction or that is located in a jurisdiction that would not be a Low-Tax Jurisdiction if its Effective Tax Rate were determined without regard to any income or expense accrued by that Entity in respect of an Intragroup Financing Arrangement;
Open s 157
Intragroup Financing Arrangement
Defined · s 157
“Intragroup Financing Arrangement” means any arrangement entered into between two or more members of the Multinational Enterprise Group whereby a High-Tax Counterparty directly or indirectly provides credit or otherwise makes an investment in a Low-Tax Entity;
Open s 157
Look-back Period
Defined · s 157
“Look-back Period” means, in respect of an election under subsections 165(16) to (19), the Election Year and the four prior Financial Years;
Open s 157
Loss Year
Defined · s 157
“Loss Year” means, in respect of jurisdiction for which the Filing Constituent Entity has made an election under subsections 165(16) to (19), a Financial Year in the Look-back Period for which there is a Net Asset Loss for a Constituent Entity located in that jurisdiction and the total amount of Net Asset Loss of all such Constituent Entities exceeds the total amount of their Net Asset Gain;
Open s 157
Low-Tax Jurisdiction
Defined · s 157
“Low-Tax Jurisdiction”, in respect of a Multinational Enterprise Group in any Financial Year, means a jurisdiction where the Multinational Enterprise Group has Net GloBE Income and is subject to an Effective Tax Rate as determined under Chapter 7 of this Part in that period that is lower than the Minimum Rate;
Open s 157
Main Entity
Defined · s 157
“Main Entity” means, in respect of a Permanent Establishment— (a) the Entity that includes the Financial Accounting Net Income or Loss of the Permanent Establishment in its financial statements; and (b) is deemed to have the Controlling Interests of its Permanent Establishment;
Open s 157
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
Net Asset Gain
Defined · s 157
“Net Asset Gain” means, in respect of an election under subsections 165(16) to (19), the net gain from the disposition of Local Tangible Assets by a Constituent Entity located in the jurisdiction for which the election was made excluding the gain or loss on a transfer of assets to another Group Member;
Open s 157
Net Asset Loss
Defined · s 157
“Net Asset Loss” means, in respect of a Constituent Entity and a Financial Year, the net loss from the disposition of Local Tangible Assets by that Constituent Entity in that year excluding the gain or loss on a transfer of assets to another Group Member. The amount of Net Asset Loss shall be reduced by the amount of Net Asset Gain or Adjusted Asset Gain which is set-off against such loss pursuant to the application of paragraph 165(18)(b) or (c) as a result of a previous election made under subsections 165(16) to (19);
Open s 157
Net GloBE Income
Defined · s 157
“Net GloBE Income” means the amount as determined in accordance with subsection 174(4);
Open s 157
Other Comprehensive Income
Defined · s 157
“Other Comprehensive Income” means items of income and expense that are not recognised in profit or loss as required or permitted by the Authorised Financial Accounting Standard used in the Consolidated Financial Statements. Other Comprehensive Income is usually reported as an adjustment to equity in the statement of financial position;
Open s 157
Pension Fund
Defined · s 157
“Pension Fund” means— (a) an Entity that is established and operated in a jurisdiction exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to persons and regulated as such by that jurisdiction or one of its political subdivisions or local authorities or those benefits are secured or otherwise protected by national regulations and funded by a pool of assets held through a fiduciary arrangement or trustor to secure the fulfilment of the corresponding pension obligations against a case of insolvency of the Multinational Enterprise Group; or (b) a Pension Services Entity;
Open s 157
Qualified Domestic Top-up Tax
Defined · s 157
“Qualified Domestic Top-up Tax” means a minimum tax that is included in the domestic law of a jurisdiction and that— (a) determines the Excess Profits of the Constituent Entities located in the jurisdiction in a manner that is equivalent to the GloBE Rules; (b) operates to increase domestic tax liability with respect to domestic Excess Profits to the Minimum Rate for the jurisdiction and Constituent Entities for a Financial Year; (c) is implemented and administered in a way that is consistent with the outcomes provided for under the GloBE Model Rules and GloBE Rules Commentary and that jurisdiction does not provide any benefits that are related to such rules; and (d) may compute domestic Excess Profits based on an Acceptable Financial Accounting Standard permitted by the Authorised Accounting Body or an Authorised Financial Accounting Standard adjusted to prevent any Material Competitive Distortions, rather than the financial accounting standard used in the Consolidated Financial Statements;
Open s 157
Tax
Defined · s 157
“Tax” means a compulsory unrequited payment to General Government;
Open s 157
Ultimate Parent Entity
Defined · s 157
“Ultimate Parent Entity” means either— (a) an Entity that— (i) owns directly or indirectly a Controlling Interest in any other Entity; and (ii) is not owned, with a Controlling Interest, directly or indirectly by another Entity; or (b) the Main Entity of a Group that is located in one jurisdiction and has one or more Permanent Establishments located in other jurisdictions provided that the Entity is not a part of another Group;
Open s 157

Report

Read on from s 166

Chapter 6

Read on from Chapter 6

Chapter 7

Read on from Chapter 7

Chapter 8

Read on from Chapter 8

Chapter 9

Read on from Chapter 9

Chapter 10

Read on from Chapter 10

Chapter 11

Read on from Chapter 11

Chapter 12

Read on from Chapter 12

Chapter 13

Read on from Chapter 13

Part XI

Read on from Part XI

Chapter 14

Read on from Chapter 14

Chapter 15

Read on from Chapter 15

Chapter 16

Read on from Chapter 16

Chapter 17

Read on from Chapter 17

Chapter 18

Read on from Chapter 18

Chapter 19

Read on from Chapter 19

Chapter III

Amendments to the Real Property Gains Tax Act 1976

Read on from Chapter III

Chapter IV

Amendments to the Stamp Act 1949

Read on from Chapter IV

Chapter V

Amendments to the Petroleum (Income Tax) Act 1967

Read on from Chapter V

Chapter VI

Amendments to the Labuan Business Activity Tax Act 1990

Read on from Chapter VI

Chapter VII

Amendment to the Entertainments Duty Act 1953

Read on from Chapter VII

Chapter VIII

Amendment to the Customs Act 1967

Read on from Chapter VIII

Chapter IX

Amendment to the Excise Act 1976

Read on from Chapter IX

Chapter X

Amendment to the Goods Vehicle Levy Act 1983

Read on from Chapter X

Chapter XI

Amendment to the Windfall Profit Levy Act 1998

Read on from Chapter XI

Chapter XII

Read on from Chapter XII

Chapter XIII

Amendments to the Sales Tax Act 2018

Read on from Chapter XIII

Chapter XIV

Amendments to the Service Tax Act 2018

Read on from Chapter XIV

Chapter XV

Amendment to the Departure Levy Act 2019

Read on from Chapter XV