Seksyen 163
Income Inclusion Rule offset mechanism
ActIn forceProvision 37 of 226
Seksyen 163
(1)
A Parent Entity that owns an Ownership Interest in a Low-Taxed Constituent Entity indirectly through an
Intermediate Parent Entity or a Partially-Owned Parent Entity which is not excluded from the Income Inclusion Rule under subsection 161(3) or (5) shall reduce its Allocable Share of a Multinational Top-up Tax of the Low-Taxed Constituent
Entity in accordance with subsection (2).
(2)
The reduction in subsection (1) will be an amount equal to the portion of the Parent Entity’s Allocable Share of the Multinational Top-up Tax which is included in the determination of the Qualified Income Inclusion Rule by the Intermediate Parent Entity or the Partially-Owned Parent
Entity.