Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
For the purposes of sections 2-65 and 2-70 , if a Constituent Entity of an MNE Group is a Flow-through Entity that is a Stateless Constituent Entity: (a) allocate, in accordance with subsection (2) , the employees and the Net Book Value of Tangible Assets of the Flow-through Entity to the Constituent Entities (if any) of the MNE Group that are located in the jurisdiction in which the Flow-through Entity was created (each of which is a receiving Constituent Entity ); and (b) to the extent that the employees and the Net Book Value of Tangible Assets of the Flow-through Entity are not allocated under paragraph (a) - disregard the employees and the Net Book Value of Tangible Assets.
2-95(2)
The number of employees of the Flow-through Entity, or the Net Book Value of Tangible Assets of the Flow-through Entity, that are allocated under paragraph (1)(a) to a receiving Constituent Entity is: (a) the number of those employees, or that Net Book Value of Tangible Assets;
multiplied by:
(b) the percentage computed under the formula in subsection 2-70(3) in respect of the receiving Constituent Entity.2-95(3)
If the Flow-through Entity is a Main Entity in respect of a Permanent Establishment, subsection (1) operates subject to section 2-90 .
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