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 10-55   MEANING OF HYBRID ENTITY  

10-55(1)    
An Entity that is treated as a separate taxable person for income tax purposes in the jurisdiction where it is located is a Hybrid Entity with respect to its income, expenditure, profit or loss, to the extent that it is fiscally transparent in the jurisdiction in which its owner is located.

10-55(2)    

An Entity that is located in a jurisdiction that has no corporate income tax system is also a Hybrid Entity with respect to its income, expenditure, profit or loss, to the extent that:

(a)    it is fiscally transparent in the jurisdiction in which its owner is located; and

(b)    section 10-50 does not apply to the Entity.