Taxes Consolidation Act 1997 section 111T

Covered taxes

Section 111T defines which taxes are included in, and which are excluded from, the concept of "covered taxes" for a constituent entity within a multinational group subject to the global minimum tax rules.

• Covered taxes include taxes on income or profits recorded in a constituent entity's accounts, taxes on distributed or deemed profits under eligible distribution tax systems, taxes imposed instead of a general corporate income tax, and taxes based on retained earnings or corporate equity.
• Top-up taxes arising under a qualified income inclusion rule (IIR), a qualified domestic top-up tax, or adjustments under a qualified undertaxed profits rule (UTPR) are all excluded from covered taxes.
• Disqualified refundable imputation taxes and taxes paid by insurance companies on policyholder returns are also excluded.
• Covered taxes relating to gains or losses on the disposal of local tangible assets in the year an election under section 111P(7)(a) is made are excluded from the covered taxes calculation.

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