Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
A Parent Entity of an MNE Group ' s Allocable Share of the Top-up Tax of a Low-Taxed Constituent Entity is reduced if: (a) the Parent Entity holds an Indirect Ownership Interest in the Low-Taxed Constituent Entity through an Intermediate Parent Entity or a Partially-Owned Parent Entity of the MNE Group; and (b) the Intermediate Parent Entity or a Partially-Owned Parent Entity is not eligible for an exclusion under subsection 2-5(5) , or an equivalent law of a non-Australian jurisdiction.
2-20(2)
The amount of the reduction is the portion of the Parent Entity ' s Allocable Share of the Top-up Tax that is brought into charge by the Intermediate Parent Entity or the Partially-Owned Parent Entity under a Qualified IIR.
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