Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
7‑165 Deemed distributions7‑165 Deemed distributions
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7‑165 Deemed distributions
(1) This section applies if: (a) an Investment Entity is a Constituent Entity of an MNE Group; and (b) there is an Undistributed Net GloBE Income Account for the Investment Entity for a Fiscal Year; and (c) the balance of the Undistributed Net GloBE Income Account is above zero at the end of the Fiscal Year; and (d) a Constituent Entity‑owner of the Investment Entity has a proportionate share of the Undistributed Net GloBE Income Account at a time in the Fiscal Year; and (e) an Ownership Interest of the Constituent Entity‑owner in the Investment Entity is transferred at that time to an Entity that is not a Group Entity of the MNE Group. (2) For the purposes of this Part: (a) treat the Investment Entity as having made a deemed distribution to the Constituent Entity‑owner at that time; and (b) treat the amount of the deemed distribution as being the amount of the proportionate share at that time (disregarding this section).