Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024
An Entity is an Excluded Service Entity if: (a) at least 95% of the value of the Entity is owned (directly or through a chain of Excluded Entities) by one or more of the following (other than a Pension Services Entity):
(i) an Excluded Entity under paragraph 20(1)(a) , (b) , (c) , (d) , (e) or (f) ;
(b) any of the following conditions are satisfied:
(ii) if the Entity is an Ultimate Parent Entity - an Investment Fund or a Real Estate Investment Vehicle; and
(i) the Entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of the Entities mentioned in paragraph (a) ;
(ii) the Entity only carries out activities that are ancillary to those carried out by the Entities mentioned in paragraph (a) .
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