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

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 2 - Transitional CbCR Safe Harbour  

Subdivision G - Treatment of Hybrid Arbitrage Arrangements  

SECTION 8-135  

8-135   ENTITIES TREATED AS CONSTITUENT ENTITIES FOR PURPOSES OF THIS SUBDIVISION  
For the purposes of this Subdivision, treat each of the following as a Constituent Entity of an MNE Group:

(a)    a Joint Venture of the MNE Group;

(b)    a JV Subsidiary of a Joint Venture of the MNE Group.