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

CHAPTER 10 - DEFINITIONS  

PART 10-1 - DEFINED TERMS  

SECTION 10-20  

10-20   DIRECT OWNERSHIP INTEREST - INTEREST DIFFERENTLY CLASSIFIED  
For the purposes of subsection 38(3) of the Act, if:

(a)    a Constituent Entity of an MNE Group (the holder ) holds an interest in another Constituent Entity of the MNE Group (the issuer ); and

(b)    the holder has classified the interest as debt under the financial accounting standard used in the preparation of the relevant Consolidated Financial Statements; and

(c)    the issuer has classified the interest as equity under that financial accounting standard;

the interest is not a Direct Ownership Interest in the issuer.