Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 10
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DEFINITIONS
PART 10-2
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DEFINITIONS OF SECURITISATION ENTITY, FLOW-THROUGH ENTITY, TAX TRANSPARENT ENTITY, REVERSE HYBRID ENTITY, AND HYBRID ENTITY
SECTION 10-45
FISCAL TRANSPARENCY AND MEANING OF TAX TRANSPARENT STRUCTURE
10-45(1)
For the purposes of this Part, treat an Entity as fiscally transparent under the laws of a jurisdiction, if that jurisdiction treats the income, expenditure, profit or loss of that Entity as if it were derived or incurred by the direct owner of that Entity in proportion to its interest in that Entity.
10-45(2)
An Ownership Interest in an Entity or a Permanent Establishment that is a Constituent Entity is held through a Tax Transparent Structure if that Ownership Interest is an Indirect Ownership Interest held through a chain of Tax Transparent Entities.
For the purposes of this Part, treat an Entity as fiscally transparent under the laws of a jurisdiction, if that jurisdiction treats the income, expenditure, profit or loss of that Entity as if it were derived or incurred by the direct owner of that Entity in proportion to its interest in that Entity.
10-45(2)
An Ownership Interest in an Entity or a Permanent Establishment that is a Constituent Entity is held through a Tax Transparent Structure if that Ownership Interest is an Indirect Ownership Interest held through a chain of Tax Transparent Entities.
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