Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑185 Meaning of Intragroup Financing Ar3‑185 Meaning of Intragroup Financing Arrangement
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3‑185 Meaning of Intragroup Financing Arrangement
An Intragroup Financing Arrangement for a Fiscal Year is an arrangement in respect of which all of the following apply: (a) the arrangement is entered into between 2 or more Constituent Entities of an MNE Group; (b) under the arrangement, one of the Constituent Entities (the investor) directly or indirectly provides credit to, or otherwise makes an investment in, another of the Constituent Entities (the recipient); (c) the investor is a High‑Tax Counterparty for the Fiscal Year; (d) the recipient is a Low‑Tax Entity for the Fiscal Year.