Section 8‑105 Transitional CbCR Safe Harbour—exc - Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 - 8‑105 Transitional CbCR Safe Harbour—exclusions

8‑105 Transitional CbCR Safe Harbour—exc8‑105 Transitional CbCR Safe Harbour—exclusions

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8‑105 Transitional CbCR Safe Harbour—exclusions

Section 8‑10 does not apply in relation to an MNE Group for a jurisdiction for a Fiscal Year if any of the following conditions are satisfied: (a) the jurisdiction is a jurisdiction in which a Stateless Constituent Entity is taken to be located under section 5‑45; (b) the MNE Group is a combined MNE Group referred to in paragraph 6‑80(2)(a) (Multi‑Parented MNE Groups) and there is no single Qualified CbC Report that includes the information of the all the separate Groups referred to in that paragraph; (c) an election for the MNE Group under section 7‑40 (Deemed Distribution Tax election) applies to the Fiscal Year and the jurisdiction; (d) all of the following conditions are satisfied: (i) in a previous Fiscal Year, one or more Constituent Entities of the MNE Group were located in the jurisdiction; (ii) section 8‑10 did not apply in relation to the MNE Group for the jurisdiction for the previous Fiscal Year; (iii) the MNE Group was an Applicable MNE Group for the previous Fiscal Year.