Document ID: chunk:federal_register_of_legislation:F2024L01740:reg:10:p5
Version: federal_register_of_legislation:F2024L01740
Segment Type: reg
Provision Reference: reg 10 (pt 5/10)
Character Range: 361667–364656

Dividends or Excluded Equity Gain or Loss that is excluded from the computation of GloBE Income or Loss under section 3‑20 or 3‑30.
Jurisdictional Top‑up Tax: see section 5‑30.
Local Tangible Asset: see section 3‑170.
Look‑back Period: see section 3‑175.
Loss Year: see section 3‑175.
Low‑Taxed Constituent Entity, of an MNE Group for a Fiscal Year, means either of the following:
 (a) a Constituent Entity of the MNE Group that is located in a Low‑Tax Jurisdiction;
 (b) a Stateless Constituent Entity of the MNE Group that has GloBE Income and an Effective Tax Rate for the Fiscal Year that is lower than the Minimum Rate.
Note: See also subsections 5‑95(5) and 5‑100(4) and paragraphs 7‑155(3)(a) and 7‑170(3)(a).
Low‑Tax Entity: see section 3‑190.
Low‑Tax Jurisdiction: see section 3‑195.
Marketable Price Floor: see subsection 3‑135(1).
Marketable Transferable Tax Credit: see section 3‑130.
Minimum Rate means 15%.
Minority‑Owned Constituent Entity: see subsection 5‑130(1).
Minority‑Owned Parent Entity: see subsection 5‑130(2).
Minority‑Owned Subgroup: see subsection 5‑135(2).
Minority‑Owned Subsidiary: see subsection 5‑135(1).
Multi‑Parented MNE Group: see subsection 6‑85(1).
Net Asset Gain: see section 3‑170.
Net Asset Loss: see section 3‑170.
Net Book Value of Tangible Assets: see section 2‑80.
Net GloBE Income: see section 5‑15.
Net GloBE Loss: see section 5‑15.
Net Unrealised Fair Value Loss: see subsection 8‑100(2).
Non‑Marketable Transferable Tax Credit: see section 3‑140.
Non‑material Constituent Entity (or NMCE): see section 8‑185.
Non‑Qualified Refundable Tax Credit: see subsection 3‑125(3).
Non‑qualifying Gain or Loss: see subsection 6‑65(4).
OECD Model Tax Convention means the Model Tax Convention on Income and on Capital published (from time to time) by the Council of the OECD.
OECD Securitisation Entity: see subsection 8‑215(1).
Other Comprehensive Income: see subsection 3‑50(2).
Other Tax Credit: see subsection 3‑140(3).
Parent Entity means:
 (a) an Ultimate Parent Entity that is not an Excluded Entity; or
 (b) an Intermediate Parent Entity; or
 (c) a Partially‑Owned Parent Entity.
Partially‑Owned Parent Entity means a Constituent Entity of an MNE Group (other than an Ultimate Parent Entity, Permanent Establishment, Investment Entity or Insurance Investment Entity):
 (a) that holds an Ownership Interest in another Constituent Entity of the MNE Group; and
 (b) in which Ownership Interests carrying rights to more than 20% of its profits are held by persons that are not Constituent Entities of the MNE Group.
Passive Income means income included in GloBE Income that is any of the following:
 (a) a dividend or dividend equivalents;
 (b) interest or interest equivalent;
 (c) rent;
 (d) royalty;
 (e) annuity;
 (f) net gains from property of a type that produces income described in paragraphs (a) to (e);
but only to the extent a Constituent Entity‑owner is subject to Tax on such income under a Controlled Foreign Company Tax Regime or as