Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
6‑20 Target’s assets etc. included in MN6‑20 Target’s assets etc. included in MNE Group’s Consolidated Financial Statements
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6‑20 Target’s assets etc. included in MNE Group’s Consolidated Financial Statements
(1) For the purposes of this instrument, if any portion of the target’s assets, liabilities, income, expenses or cash flows are included on a line‑by‑line basis in the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group in the transfer year: (a) in applying this instrument in relation to the disposing MNE Group, treat the target as a Constituent Entity of that MNE Group for the transfer year; and (b) the rules set out in sections 6‑25 to 6‑45 apply. (2) For the purposes of this instrument, if any portion of the target’s assets, liabilities, income, expenses or cash flows are included on a line‑by‑line basis in the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group in the transfer year: (a) in applying this instrument in relation to the acquiring MNE Group, treat the target as a Constituent Entity of that MNE Group for the transfer year; and (b) the rules set out in sections 6‑25 to 6‑45 apply. (3) To avoid doubt, if both subparagraphs 6‑15(1)(b)(i) and (ii) apply in the transfer year, the target may be treated as a Constituent Entity of both MNE Groups under subsections (1) and (2).