Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
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For the purposes of subsection 38(3) of the Act, if: (a) a Constituent Entity of an MNE Group (the holder) holds an interest in another Constituent Entity of the MNE Group (the issuer); and (b) the holder has classified the interest as debt under the financial accounting standard used in the preparation of the relevant Consolidated Financial Statements; and (c) the issuer has classified the interest as equity under that financial accounting standard; the interest is not a Direct Ownership Interest in the issuer.