§ 62 — Relief against double-counting

62.—(1) Where a joint venture or JV subsidiary (X) connected to an MNE group is also a joint venture or JV subsidiary connected to another MNE group and DTT is payable in respect of both MNE groups for a financial year, the designated local DTT filing entity of any of those MNE groups (called in this section the applicant MNE group) may apply to the Comptroller for relief against double‑counting of DTT for that financial year.(2) The application must be made in the return to be filed under section 43 for that financial year.

(3) The amount of relief for the applicant MNE group is determined by the formula where —(a)

A is the GloBE income or loss of X for the financial year that is attributable to the ownership interests of the ultimate parent entity of the other MNE group in X;

(b)

B is the GloBE income or loss of X for the financial year; and

(c)

C is the top‑up amount of the applicant MNE group attributable to X for the financial year, as determined under section 45(4).

(4) The amount of relief computed under subsection (3) is to be deducted against the DTT payable in respect of the relevant chargeable entity of the applicant MNE group in that subsection for the financial year.

—(1) Where a joint venture or JV subsidiary (X) connected to an MNE group is also a joint venture or JV subsidiary connected to another MNE group and DTT is payable in respect of both MNE groups for a financial year, the designated local DTT filing entity of any of those MNE groups (called in this section the applicant MNE group) may apply to the Comptroller for relief against double‑counting of DTT for that financial year.

(2) The application must be made in the return to be filed under section 43 for that financial year.

(3) The amount of relief for the applicant MNE group is determined by the formula where —(a)

A is the GloBE income or loss of X for the financial year that is attributable to the ownership interests of the ultimate parent entity of the other MNE group in X;

(b)

B is the GloBE income or loss of X for the financial year; and

(c)

C is the top‑up amount of the applicant MNE group attributable to X for the financial year, as determined under section 45(4).

(4) The amount of relief computed under subsection (3) is to be deducted against the DTT payable in respect of the relevant chargeable entity of the applicant MNE group in that subsection for the financial year.