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TAXATION (MULTINATIONAL--GLOBAL AND DOMESTIC MINIMUM TAX) ACT 2024 (NO. 132, 2024) - SECT 26

Joint Ventures

  (1)   An Entity is a Joint Venture of an MNE Group if:

  (a)   the Entity's financial results are reported under the equity method in the Consolidated Financial Statements of the Ultimate Parent Entity   of the MNE Group for the Fiscal Year; and

  (b)   the Ultimate Parent Entity's Ownership Interest Percentage in the Entity is at least 50%.

  (2)   However, the Entity is not a Joint Venture of an MNE Group if any of the following applies:

  (a)   the Entity is the Ultimate Parent Entity of an Applicable MNE Group;

  (b)   the Entity is an Excluded Entity under paragraph   20(1)(a), (b), (c), (d), (e) or (f);

  (c)   in a case where the Group Entities of the MNE Group that hold Direct Ownership Interests in the Entity   (the Excluded Entity owners ) are Excluded Entities mentioned in paragraph   (b) of this subsection--any of the following applies:

  (i)   the Entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of the holders of Direct Ownership Interests in the Entity;

  (ii)   the Entity only carries out activities that are ancillary to those carried out by the Excluded Entity owners;

  (iii)   the Entity is of a kind prescribed by the Rules for the purposes of this subparagraph;

  (d)   the MNE Group is comprised exclusively of Excluded Entities;

  (e)   the Entity is a JV Subsidiary of a Joint Venture.



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