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Table of Contents
Global Minimum Tax Act, 2024 (Act No. 46 of 2024)
Notice No. 5740 of 2024
Act
Preamble
Part I : Interpretation
1. Definitions
Part II : Application of GloBE Model Rules
2. Application of GloBE Model Rules
3. Application of GloBE Model Rules to Republic
Part III : Income Inclusion Rule
4. Charge to Tax for Constituent Entities
5. Inapplicable articles in GloBE Model Rules
Part IV : Domestic Minimum Top-up Tax
A. Constituent Entity liability
6. Charge to Tax for Domestic Constituent Entities
7. Charge to Tax for Domestic Joint Ventures
8. Calculation of Domestic Minimum Top-up Tax
B. Articles that do not apply
9. Inapplicable articles in GloBE Model Rules
10. Qualified Domestic Minimum Top-up Tax
11. Inapplicable Safe Harbours
C. Computation of Adjusted Covered Taxes
12. Exclusion of certain foreign taxes on domestic income
13. Exclusion of domestic taxes on certain foreign income
D. Computation of Top-up Tax
14. Total Top-up Tax of Domestic Constituent Entities of MNE Group
15. Top-up Tax of Domestic Joint Venture Group
16. Domestic Minimum Top-up Tax
E. Transition Rules
17. Transition Year
18. Later Transition Year
19. Effect of change in Transition Year
Part V : Imposition of and liability for top-up tax
20. Imposition of top-up tax
21. Persons subject to tax
22. Top-up tax liability in domestic currency
Part VI : General provisions
23. Amendments of international standards
24. Regulations by Minister
25. Short title and commencement
‘‘Minister’’
means the Minister of Finance;
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