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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-6 - MINORITY-OWNED CONSTITUENT ENTITIES  

SECTION 5-130   MEANING OF MINORITY-OWNED CONSTITUENT ENTITY AND MINORITY-OWNED PARENT ENTITY  

5-130(1)    
A Constituent Entity of an MNE Group is a Minority-Owned Constituent Entity if the Ultimate Parent Entity of the MNE Group has an Ownership Interest Percentage in the Constituent Entity of 30% or less.

5-130(2)    
A Minority-Owned Constituent Entity is a Minority-Owned Parent Entity if:

(a)    it holds a Controlling Interest in another Minority-Owned Constituent Entity; and

(b)    a Controlling Interest in it is not held by another Minority-Owned Constituent Entity.