Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
8‑85 Transitional CbCR Safe Harbour—spec8‑85 Transitional CbCR Safe Harbour—special rule for Ultimate Parent Entity that is Flow‑through Entity
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8‑85 Transitional CbCR Safe Harbour—special rule for Ultimate Parent Entity that is Flow‑through Entity
(1) This section applies if a Constituent Entity of an MNE Group is: (a) the Ultimate Parent Entity of the MNE Group; and (b) a Flow‑through Entity; and (c) located in a jurisdiction for a Fiscal Year. (2) Subsection (3) applies in relation to the Fiscal Year if there are Direct Ownership Interests in the Ultimate Parent Entity that are not held by a holder described in paragraph 7‑5(2)(a), (b) or (c). (3) Section 8‑10 does not apply in relation to the MNE Group for the jurisdiction for the Fiscal Year. (4) Subsection (5) applies if subsection (3) does not apply. (5) For the purposes of section 8‑10, in computing the MNE Group’s Profit (Loss) before Income Tax, and Simplified Covered Taxes, for the jurisdiction for the Fiscal Year, disregard amounts to the extent that they are attributable to a Direct Ownership Interest in the Ultimate Parent Entity held by a holder described in paragraph 7‑5(2)(a), (b) or (c).