Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024
This section applies if an Entity that is located in a jurisdiction is a Main Entity in respect of one or more Permanent Establishments that are located in other jurisdictions.
18(2)
For the purposes of this Act: (a) each of those Permanent Establishments is taken to be separate from the Main Entity and from each other; and (b) the Main Entity is taken to hold a Controlling Interest in each of those Permanent Establishments.
Note:
The Main Entity is taken to hold a Direct Ownership Interest in each of those Permanent Establishments: see subsection 38(4) .
18(3)
If the Entity is a Group Entity of a Group under subsection 17(1) and is not an Excluded Entity, the Main Entity and each of those Permanent Establishments is a Constituent Entity of the Group.
18(4)
If the Entity is not a Group Entity of a Group under subsection 17(1) : (a) the Entity is a Group under this paragraph and a Group Entity of the Group; and (b) where the Entity is not an Excluded Entity - the Main Entity and each of those Permanent Establishments is a Constituent Entity of the Group; and (c) the Main Entity is the Ultimate Parent Entity of the Group.
Note:
For the purposes of this section, a Governmental Entity that meets the criterion in subparagraph 21(1)(b)(ii) (a sovereign wealth fund) is treated as not being an Entity: see subsection 21(2) .
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