INTERNATIONAL TAX PLAZA - Qualified Income Inclusion Rule

Details: Published: 16 February 2022

‘Qualified income inclusion rule’ (‘Qualified IIR’) means a set of rules that is implemented in the domestic law of a jurisdiction and that:

(a) is equivalent to the rules laid down in the proposed Directive in accordance with which the parent entity of an MNE Group computes and collects its allocable share of top-up tax in respect of the low-taxed constituent entities of the group;

(b) is implemented and administered in a way that is consistent with the rules laid down in the proposed Directive and does not allow the jurisdiction to provide any benefits that are related to those rules.

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