Taxation (Multinational - Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (F2026L00908)

Schedule 1   Amendments

Part 3   Amendments relating to Flow-through Entities

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

19   Section 10-35

Repeal the section, substitute:

10 - 35 Meaning of Tax Transparent Entity

A Flow-through Entity is a Tax Transparent Entity with respect to its income, expenditure, profit or loss to the extent that:

(a) the Flow-through Entity is fiscally transparent in the jurisdiction in which its Reference Entity is located; and

(b) each Entity through which the Reference Entity holds its Ownership Interest in the Flow-through Entity is fiscally transparent in the jurisdiction in which the Reference Entity is located.

Note: A Constituent Entity may be treated as a Tax Transparent Entity in accordance with section 10-50.