Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES

PART 6-2 - CONSTITUENT ENTITIES JOINING AND LEAVING AN MNE GROUP

Division 1 - Transfers of Ownership Interests

SECTION 6-45

6-45 TARGET ' S TOP-UP TAX IF PARENT ENTITY IN 2 OR MORE MNE GROUPS
If, in the transfer year, the target is:

(a) a Parent Entity; and

(b) a Group Entity of 2 or more MNE Groups;

in computing the Top-up Tax of the target for the transfer year, apply the provisions of this instrument separately in relation to each of the MNE Groups.

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