Taxation (Multinational - Global and Domestic Minimum Tax) Amendment (2026 Measures No. 1) Rules 2026 (F2026L00371)
Schedule 1 Amendments
Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
5 Paragraph 2-25(5)(a)
Repeal the paragraph, substitute:
(a) a Joint Venture of an MNE Group, or a JV Subsidiary of a Joint Venture of an MNE Group is:
(i) located in Australia for a Fiscal Year; or
(ii) a Flow-through Entity created in Australia, and, under paragraph 6-75(2)(c), treated as a Stateless Constituent Entity for a Fiscal Year; or
(iii) treated under paragraph 6-75(2)(c) as a Stateless Constituent Entity that is a Permanent Establishment in relation to which paragraph 19(1)(d) of the Act applies, and a place of business (including a deemed place of business) in Australia, for a Fiscal Year; and