Taxation (Multinational - Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (F2026L00908)

Schedule 1   Amendments

Part 3   Amendments relating to Flow-through Entities

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

18   Section 10-5

Insert:

Reference Entity : an Entity is a Reference Entity of a Flow-through Entity, in relation to an Ownership Interest, if the Entity is:

(a) the holder (the direct owner ) of a Direct Ownership Interest in relation to the Ownership Interest and is not a Flow-through Entity; or

(b) if paragraph (a) does not apply - the next holder of the Ownership Interest in the ownership chain, after the direct owner, that is not a Flow-through Entity; or

(c) if paragraphs (a) and (b) do not apply - the Ultimate Parent Entity of the Flow-through Entity in relation to the Ownership Interest.