Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
For the purposes of this instrument, if any portion of the target ' s assets, liabilities, income, expenses or cash flows are included on a line-by-line basis in the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group in the transfer year: (a) in applying this instrument in relation to the disposing MNE Group, treat the target as a Constituent Entity of that MNE Group for the transfer year; and (b) the rules set out in sections 6-25 to 6-45 apply.
6-20(2)
For the purposes of this instrument, if any portion of the target ' s assets, liabilities, income, expenses or cash flows are included on a line-by-line basis in the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group in the transfer year: (a) in applying this instrument in relation to the acquiring MNE Group, treat the target as a Constituent Entity of that MNE Group for the transfer year; and (b) the rules set out in sections 6-25 to 6-45 apply.
6-20(3)
To avoid doubt, if both subparagraphs 6-15(1)(b)(i) and (ii) apply in the transfer year, the target may be treated as a Constituent Entity of both MNE Groups under subsections (1) and (2) .
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