Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024
PART 5
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INTERPRETATION
Division 4
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Location of Entities and Permanent Establishments
SECTION 41
LOCATION OF AN ENTITY THAT IS A FLOW-THROUGH ENTITY
41(1)
This section applies to an Entity if it is a Flow-through Entity.
41(2)
For the purposes of this Act, the Entity is located in the jurisdiction in which the Entity was created if: (a) the Entity is an Ultimate Parent Entity; or (b) the Entity is required to apply a Qualified IIR.
41(3)
For the purposes of this Act, if: (a) subsection (2) does not apply to the Entity; and (b) the Entity is a Constituent Entity of an MNE Group;
This section applies to an Entity if it is a Flow-through Entity.
41(2)
For the purposes of this Act, the Entity is located in the jurisdiction in which the Entity was created if: (a) the Entity is an Ultimate Parent Entity; or (b) the Entity is required to apply a Qualified IIR.
41(3)
For the purposes of this Act, if: (a) subsection (2) does not apply to the Entity; and (b) the Entity is a Constituent Entity of an MNE Group;
the Entity is a Stateless Constituent Entity of the MNE Group.
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