Schedules

Schedule 16Multinational top-up tax: transitional provision

Part 2Transitional safe harbour

Chapter 1Transitional safe harbour election

8Simplified effective tax rate test

1

The simplified effective tax rate test is met for a territory in an accounting period if the simplified effective tax rate of the standard members of the group in that territory is—

a

in the case of an accounting period beginning before 1 January 2025, at least 15%,

b

in the case of an accounting period beginning in 2025, at least 16%, or

c

in the case of an accounting period beginning on or after 1 January 2026, at least 17%.

2

The simplified effective tax rate of the standard members of a multinational group in a territory in an accounting period is the amount (expressed as a percentage) given by dividing—

a

the aggregate qualifying income tax expense of those members for that period, by

b

the aggregate profit (loss) before income tax of those members for that period.