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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-1 - ULTIMATE PARENT ENTITY THAT IS A FLOW-THROUGH ENTITY  

SECTION 7-10   FLOW-THROUGH ENTITY THAT IS ULTIMATE PARENT ENTITY - REDUCE GloBE LOSS  

7-10(1)    
This section applies if:

(a)    the Ultimate Parent Entity of an MNE Group is a Flow-through Entity; and

(b)    an amount (the attributable loss ) of the Ultimate Parent Entity ' s GloBE Loss for a Fiscal Year is attributable to a Direct Ownership Interest held by another Entity in the Ultimate Parent Entity.

7-10(2)    
Reduce the Ultimate Parent Entity ' s GloBE Loss for the Fiscal Year by the attributable loss (but not below zero), except to the extent that the holder of the Ownership Interest is not allowed to use the attributable loss in computing their separate taxable income.