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.