Regulation 55
Adjustment to substance-based income exclusion due to eligible tangible assets being located in and outside constituent entity’s jurisdiction
of Multinational Enterprise (Minimum Tax) Regulations 2024
If the percentage of the duration (Y%) within a financial year in which an eligible tangible asset of a constituent entity of an MNE group is located in the same jurisdiction as the constituent entity is 50% or less of the total duration of the financial year, then, for determining the tangible asset carve‑out amount of a constituent entity for that financial year, the carrying value of the asset for that financial year is the product of —
the carrying value of the asset adjusted (if applicable) in accordance with section 18(5) and (6) and regulation 57; and
Y%.