Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024
An Entity is a Joint Venture of an MNE Group if: (a) the Entity ' s financial results are reported under the equity method in the Consolidated Financial Statements of the Ultimate Parent Entity of the MNE Group for the Fiscal Year; and (b) the Ultimate Parent Entity ' s Ownership Interest Percentage in the Entity is at least 50%.
26(2)
However, the Entity is not a Joint Venture of an MNE Group if any of the following applies: (a) the Entity is the Ultimate Parent Entity of an Applicable MNE Group; (b) the Entity is an Excluded Entity under paragraph 20(1)(a) , (b) , (c) , (d) , (e) or (f) ; (c) in a case where the Group Entities of the MNE Group that hold Direct Ownership Interests in the Entity (the Excluded Entity owners ) are Excluded Entities mentioned in paragraph (b) of this subsection - any of the following applies:
(i) the Entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of the holders of Direct Ownership Interests in the Entity;
(ii) the Entity only carries out activities that are ancillary to those carried out by the Excluded Entity owners;
(d) the MNE Group is comprised exclusively of Excluded Entities; (e) the Entity is a JV Subsidiary of a Joint Venture.
(iii) the Entity is of a kind prescribed by the Rules for the purposes of this subparagraph;
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