Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
2‑95 Employees and the Net Book Value of2‑95 Employees and the Net Book Value of Tangible Assets allocated from Flow‑through Entity
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2‑95 Employees and the Net Book Value of Tangible Assets allocated from Flow‑through Entity
(1) For the purposes of sections 2‑65 and 2‑70, if a Constituent Entity of an MNE Group is a Flow‑through Entity that is a Stateless Constituent Entity: (a) allocate, in accordance with subsection (2), the employees and the Net Book Value of Tangible Assets of the Flow‑through Entity to the Constituent Entities (if any) of the MNE Group that are located in the jurisdiction in which the Flow‑through Entity was created (each of which is a receiving Constituent Entity); and (b) to the extent that the employees and the Net Book Value of Tangible Assets of the Flow‑through Entity are not allocated under paragraph (a)—disregard the employees and the Net Book Value of Tangible Assets. (2) The number of employees of the Flow‑through Entity, or the Net Book Value of Tangible Assets of the Flow‑through Entity, that are allocated under paragraph (1)(a) to a receiving Constituent Entity is: (a) the number of those employees, or that Net Book Value of Tangible Assets; multiplied by: (b) the percentage computed under the formula in subsection 2‑70(3) in respect of the receiving Constituent Entity. (3) If the Flow‑through Entity is a Main Entity in respect of a Permanent Establishment, subsection (1) operates subject to section 2‑90.
Chapter 3—Computation of GloBE Income or Loss