2‑30 Amount of Domestic Top‑up Tax Amoun

2‑30 Amount of Domestic Top‑up Tax Amount

Constituent Entities generally and Permanent Establishments (1) For the purposes of subsection 2‑25(2) or (4), the amount of the Domestic Top‑up Tax Amount is equal to the amount of the Top‑up Tax mentioned in that subsection, computed in accordance with the principles set out in section 2‑35. Joint Ventures and JV Subsidiaries (2) For the purposes of subsection 2‑25(6) or (8), the amount of the Domestic Top‑up Tax Amount is equal to the amount of the Top‑up Tax mentioned in that subsection, computed in accordance with the principles set out in sections 2‑35 and 6‑75. (3) Subsection (4) applies if: (a) any of the following circumstances exist: (i) a Joint Venture of an MNE Group is also a Joint Venture of another MNE Group; (ii) a JV Subsidiary of a Joint Venture of an MNE Group is also a JV Subsidiary of a Joint Venture of another MNE Group; and (b) as a result of those circumstances, subsection 2‑25(6) or (8) applies to the Joint Venture, or the JV Subsidiary, for a Fiscal Year, in relation to each of the MNE Groups. (4) Treat the reference in subsection (2) to “the amount of the Top‑up Tax” as instead being a reference to “half the amount of the Top‑up Tax”.

Note: This means that the Joint Venture or the JV Subsidiary (or if subsection 2‑25(8) applies, the Main Entity) has a Domestic Top‑up Tax Amount for the Fiscal Year of half the amount of the Top‑up Tax, in relation to each MNE Group.