Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to: (a) a specified Constituent Entity of the MNE Group that is an Investment Entity; and (b) a specified Constituent Entity-owner of the Investment Entity that:
(i) is not an Investment Entity; and
(ii) if the Constituent Entity-owner holds an Indirect Ownership Interest in the Investment Entity - holds the Indirect Ownership Interest through a chain of Investment Entities.
7-145(2)
An election under subsection (1) is a Five-Year Election.
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