Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
4‑65 Allocation of amounts from Constitu4‑65 Allocation of amounts from Constituent Entity‑owner to Hybrid Entity or Reverse Hybrid Entity
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4‑65 Allocation of amounts from Constituent Entity‑owner to Hybrid Entity or Reverse Hybrid Entity
(1) An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity‑owner of a Constituent Entity that is a Hybrid Entity to the Hybrid Entity if: (a) the Constituent Entity‑owner holds an Ownership Interest in the Hybrid Entity; and (b) the amount is: (i) accrued in the financial accounts of the Constituent Entity‑owner for the Fiscal Year; and (ii) so accrued in respect of income of the Hybrid Entity. (2) Subsection (1) applies in relation to a Constituent Entity‑owner and a Constituent Entity that is a Reverse Hybrid Entity in the same way that it applies in relation to a Constituent Entity‑owner and a Hybrid Entity.