Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
This section applies if: (a) the Ultimate Parent Entity of an MNE Group is a Flow-through Entity; and (b) either:
(i) the Ultimate Parent Entity; or
(ii) if subsection (2) applies - the Tax Transparent Entity mentioned in that subsection;
wholly or partly carries out its business through a Permanent Establishment.
7-15(2)
For the purposes of subparagraph (1)(b)(ii) , this subsection applies if the Ultimate Parent Entity holds an Ownership Interest in a Tax Transparent Entity that is: (a) a Direct Ownership Interest; or (b) an Indirect Ownership Interest held through a Tax Transparent Structure.
7-15(3)
Subsection (4) applies if an amount (the attributable income ) of the Permanent Establishment ' s GloBE Income for a Fiscal Year is attributable to a Direct Ownership Interest held by another Entity in the Ultimate Parent Entity.
7-15(4)
Subsections 7-5(2) , (3) and (4) apply to the Permanent Establishment in the same way that they apply to an Ultimate Parent Entity.
7-15(5)
Subsection (6) applies if an amount (the attributable loss ) of the Permanent Establishment ' s GloBE Loss for a Fiscal Year is attributable to a Direct Ownership Interest held by another Entity in the Ultimate Parent Entity.
7-15(6)
Subsection 7-10(2) applies to the Permanent Establishment in the same way that it applies to an Ultimate Parent Entity.
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