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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
5‑130 Meaning of Minority‑Owned Constitu5‑130 Meaning of Minority‑Owned Constituent Entity and Minority‑Owned Parent Entity
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5‑130 Meaning of Minority‑Owned Constituent Entity and Minority‑Owned Parent Entity
(1) A Constituent Entity of an MNE Group is a Minority‑Owned Constituent Entity if the Ultimate Parent Entity of the MNE Group has an Ownership Interest Percentage in the Constituent Entity of 30% or less. (2) A Minority‑Owned Constituent Entity is a Minority‑Owned Parent Entity if: (a) it holds a Controlling Interest in another Minority‑Owned Constituent Entity; and (b) a Controlling Interest in it is not held by another Minority‑Owned Constituent Entity.