Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024

PART 3 - CORE GROUP AND ENTITY CONCEPTS  

Division 2 - Excluded Entities  

SECTION 25  

25   MEANING OF EXCLUDED SERVICE ENTITY  
An Entity is an Excluded Service Entity if:

(a)    at least 95% of the value of the Entity is owned (directly or through a chain of Excluded Entities) by one or more of the following (other than a Pension Services Entity):

(i) an Excluded Entity under paragraph 20(1)(a) , (b) , (c) , (d) , (e) or (f) ;

(ii) if the Entity is an Ultimate Parent Entity - an Investment Fund or a Real Estate Investment Vehicle; and

(b)    any of the following conditions are satisfied:

(i) the Entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of the Entities mentioned in paragraph (a) ;

(ii) the Entity only carries out activities that are ancillary to those carried out by the Entities mentioned in paragraph (a) .