Regulation 44C
Cross-border allocation of deferred tax expenses
of Multinational Enterprise (Minimum Tax) Regulations 2024
Where any qualifying deferred tax expense of a constituent entity of an MNE group in a jurisdiction —
is to be allocated to another constituent entity of the MNE group in another jurisdiction pursuant to regulation 44(1), (4), (5) or (5A); or
is to be treated as the qualifying deferred tax expense of a permanent establishment of the firstmentioned constituent entity in another jurisdiction pursuant to paragraph 1(4) of the First Schedule to the Act,the allocation and treatment must be in accordance with the methodology described in Chapter 4.2 of the June 2024 Administrative Guidance, and that methodology is to apply for this purpose with the necessary modifications.