Year-specific percentages
The June 2026 slides set payroll and asset percentages at 9.6% and 7.6% for FYs beginning in 2025, 9.4% and 7.4% for 2026, progressively reaching 5% each from 2033. Apply the financial-year start, not the article’s reading date. An annual election can decline the exclusion; a claim can use all or part of qualifying costs and assets under the rules. This amount reduces excess profits for top-up purposes rather than the ETR denominator itself.
Eligibility and allocation
Payroll includes defined compensation, employment taxes and employer social contributions, with exclusions to avoid duplication in asset costs and for excluded shipping income. Employee location and time allocation matter. Tangible assets use the prescribed carrying-value and location tests, with branch and flow-through allocations matching the relevant income attribution. Keep payroll-location evidence and asset schedules connected to the constituent entities. General headcount or a consolidated fixed-asset balance alone does not establish the eligible carve-out.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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