177. Jurisdictional Top-up Tax

Terms defined in s 157

• Additional Current Multinational Top-up Tax

  Additional Current Multinational Top-up Tax

  Defined · s 157

  “Additional Current Multinational Top-up Tax” means the amount of tax determined in subsections 181(1) to (6) and any amount treated as Additional Current Multinational Top-up Tax determined under subsections 181(1) to (6), such as the amount determined under subsection 169(3) or section 191;

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• Domestic Top-up Tax

  Domestic Top-up Tax

  Defined · s 157

  “Domestic Top-up Tax” means tax as provided under section 159;

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• Excess Profit

  Excess Profit

  Defined · s 157

  “Excess Profit” means the amount computed in accordance with section 176;

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• Financial Year

  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;

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• 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;

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• Qualified Domestic Top-up Tax

  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;

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• Tax

  Tax

  Defined · s 157

  “Tax” means a compulsory unrequited payment to General Government;

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