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 10-55
10-55
MEANING OF HYBRID ENTITY
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.
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.
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