Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
This section applies if a Constituent Entity of an MNE Group is: (a) the Ultimate Parent Entity of the MNE Group; and (b) a Flow-through Entity; and (c) located in a jurisdiction for a Fiscal Year.
8-85(2)
Subsection (3) applies in relation to the Fiscal Year if there are Direct Ownership Interests in the Ultimate Parent Entity that are not held by a holder described in paragraph 7-5(2)(a) , (b) or (c) .
8-85(3)
Section 8-10 does not apply in relation to the MNE Group for the jurisdiction for the Fiscal Year.
8-85(4)
Subsection (5) applies if subsection (3) does not apply.
8-85(5)
For the purposes of section 8-10 , in computing the MNE Group ' s Profit (Loss) before Income Tax, and Simplified Covered Taxes, for the jurisdiction for the Fiscal Year, disregard amounts to the extent that they are attributable to a Direct Ownership Interest in the Ultimate Parent Entity held by a holder described in paragraph 7-5(2)(a) , (b) or (c) .
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