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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-6 - TAXABLE DISTRIBUTION METHOD ELECTION  

SECTION 7-145   TAXABLE DISTRIBUTION METHOD ELECTION  

7-145(1)    
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to:

(a)    a specified Constituent Entity of the MNE Group that is an Investment Entity; and

(b)    a specified Constituent Entity-owner of the Investment Entity that:

(i) is not an Investment Entity; and

(ii) if the Constituent Entity-owner holds an Indirect Ownership Interest in the Investment Entity - holds the Indirect Ownership Interest through a chain of Investment Entities.

7-145(2)    
An election under subsection (1) is a Five-Year Election.