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

CHAPTER 10 - DEFINITIONS  

PART 10-2 - DEFINITIONS OF SECURITISATION ENTITY, FLOW-THROUGH ENTITY, TAX TRANSPARENT ENTITY, REVERSE HYBRID ENTITY, AND HYBRID ENTITY  

SECTION 10-35  

10-35   MEANING OF TAX TRANSPARENT ENTITY  

A Flow-through Entity is a Tax Transparent Entity with respect to its income, expenditure, profit or loss to the extent that:

(a)    the Flow-through Entity is fiscally transparent in the jurisdiction in which its Reference Entity is located; and

(b)    each Entity through which the Reference Entity holds its Ownership Interest in the Flow-through Entity is fiscally transparent in the jurisdiction in which the Reference Entity is located.

Note:

A Constituent Entity may be treated as a Tax Transparent Entity in accordance with section 10-50 .