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

CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES  

PART 6-2 - CONSTITUENT ENTITIES JOINING AND LEAVING AN MNE GROUP  

Division 1 - Transfers of Ownership Interests  

SECTION 6-45  

6-45   TARGET ' S TOP-UP TAX IF PARENT ENTITY IN 2 OR MORE MNE GROUPS  
If, in the transfer year, the target is:

(a)    a Parent Entity; and

(b)    a Group Entity of 2 or more MNE Groups;

in computing the Top-up Tax of the target for the transfer year, apply the provisions of this instrument separately in relation to each of the MNE Groups.