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Global Minimum Tax Act, 2024 (Act No. 46 of 2024)

Part IV : Domestic Minimum Top-up Tax

D. Computation of Top-up Tax

16. Domestic Minimum Top-up Tax

 

(1) There shall be separate Domestic Minimum Top-up Tax calculations for Domestic Constituent Entities that are Minority-Owned Constituent Entities, Domestic Constituent Entities that are Investment Entities, Domestic Joint Venture Groups and other Domestic Constituent Entities.

 

(2) The Domestic Minimum Top-up Tax for an Investment Entity shall be calculated under Articles 7.4 to 7.6 of the GloBE Model Rules and Article 2.2.2 of the GloBE Model Rules shall be applied to the extent necessary for this purpose.

 

(3) In all other cases, the Domestic Minimum Top-up Tax shall be calculated using the following formula in lieu of the formula set out in Article 5.2.3 of the GloBE Model Rules:

 

Top-up Tax = (Top-up Tax Percentage × Excess Profits) +

Additional Current Top-up Tax