Multinational Top-up Tax and Domestic Top-up Tax

MTT61010 - Charging mechanisms: The charge: Overview

The Income Inclusion Rule (IIR) is the primary charge under MTT. Under the IIR, a responsible member (either the ultimate parent, an intermediate parent or a partially owned parent) is identified. There may be more than one responsible member in a group.

A responsible member is chargeable in respect of top-up amounts related to its foreign subsidiaries.

The top-up amount of each member of the group is attributed to its responsible members according to the ‘inclusion ratio’. Broadly, the inclusion ratio allocates the charge on the basis of the responsible member’s ownership interest in the member with the top-up amount.

See MTT61020 for guidance on chargeable persons.

See MTT61030 for guidance on responsible members.

See MTT61040 for guidance on the amount to be charged to each responsible member.

See MTT61050 and MTT61060 for guidance on how to attribute top-up amounts from a member with a top-up amount to a responsible member.

For guidance on calculating the top-up amount of a member, see MTT30000+.