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.