Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
6‑15 Application of this Division6‑15 Application of this Division
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6‑15 Application of this Division
(1) This Division applies if: (a) there is a transfer of Ownership Interests in an Entity (the target) in a Fiscal Year (the transfer year); and (b) any of the following situations result from the transfer: (i) the target becomes a Constituent Entity of an MNE Group (the acquiring MNE Group); (ii) the target ceases to be a Constituent Entity of an MNE Group (the disposing MNE Group).
Note: This Division does not apply if the transfer is treated and taxed as an asset sale by a relevant jurisdiction: see subsection 6‑50(2).
(2) To avoid doubt, the situations mentioned in paragraph (1)(b) can arise where any of the following occur: (a) the target ceases to be a Constituent Entity of the disposing MNE Group and becomes a Constituent Entity of the acquiring MNE Group; (b) the target becomes a Constituent Entity of the acquiring MNE Group because the acquiring MNE Group is a new Group and the target becomes the Ultimate Parent Entity of the acquiring MNE Group.