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Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑65 Meaning of CbCR Resident8‑65 Meaning of CbCR Resident
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8‑65 Meaning of CbCR Resident
A Constituent Entity of an MNE Group is a CbCR Resident of a jurisdiction for a Fiscal Year if: (a) it is recorded as a resident of the jurisdiction in the Country‑by‑Country Report of the MNE Group for the Fiscal Year; or (b) if subsection 8‑35(3) or (4) applies in relation to the MNE Group—the Constituent Entity would have been recorded as a resident of the jurisdiction in the data reported in the MNE Group’s Qualified CbC Report.