Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 8
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ADMINISTRATION
PART 8-2
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SAFE HARBOURS
Division 2
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Transitional CbCR Safe Harbour
Subdivision D
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Routine profits test
SECTION 8-65
8-65
MEANING OF CbCR RESIDENT
A Constituent Entity of an MNE Group is a CbCR Resident of a jurisdiction for a Fiscal Year if: (a) it is recorded as a resident of the jurisdiction in the Country-by-Country Report of the MNE Group for the Fiscal Year; or (b) if subsection 8-35(3) or (4) applies in relation to the MNE Group - the Constituent Entity would have been recorded as a resident of the jurisdiction in the data reported in the MNE Group ' s Qualified CbC Report.
A Constituent Entity of an MNE Group is a CbCR Resident of a jurisdiction for a Fiscal Year if: (a) it is recorded as a resident of the jurisdiction in the Country-by-Country Report of the MNE Group for the Fiscal Year; or (b) if subsection 8-35(3) or (4) applies in relation to the MNE Group - the Constituent Entity would have been recorded as a resident of the jurisdiction in the data reported in the MNE Group ' s Qualified CbC Report.
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