Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p114
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
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Character Range: 285167–288015

the Investment Entity's GloBE Income or Loss for the revocation year, include the Constituent Entity‑owner's proportionate share of the balance of the Undistributed Net GloBE Income Account (the Constituent Entity‑owner's undistributed share).
 (3) For purposes of Chapter 2:
 (a) treat the Investment Entity as a Low‑Taxed Constituent Entity of the MNE Group for the reporting year; and
 (b) treat the Top‑up Tax of the Investment Entity for the reporting year as being the amount equal to:
 (i) the Constituent Entity‑owner's undistributed share;
  multiplied by:
 (ii) the Minimum Rate.

Chapter 8—Administration

Part 8‑2—Safe harbours

Division 1—Preliminary

8‑5  Application of this Part to Minority‑Owned Constituent Entities, Joint Ventures and Investment Entities

Minority‑Owned Constituent Entities (MOCEs)
 (1) Subsections (2) and (3) apply unless an MNE Group meets the SC De minimis test for a jurisdiction for a Fiscal Year.
Note: In determining whether an MNE Group meets the SC De minimis test, MOCEs are not treated as if they comprised a separate MNE Group or were the only Constituent Entities of the MNE Group located in a jurisdiction.
 (2) In applying Divisions 3 and 4:
 (a) treat the purposes mentioned in subsection 5‑120(3) (MOCEs that comprise a Minority‑Owned Subgroup) as including the purposes of this Part; and
 (b) treat paragraph 8‑155(2)(a) as having been repealed.
 (3) In applying Divisions 3 and 4:
 (a) treat the purposes mentioned in subsection 5‑125(3) (MOCEs that are not part of a Minority‑Owned Subgroup treated as only Constituent Entities of the MNE Group) as including the purposes of this Part; and
 (b) treat the purposes mentioned in subsection 5‑125(5) (MOCEs that are not part of a Minority‑Owned Subgroup treated as not being Constituent Entities of the MNE Group) as including the purposes of this Part; and
 (c) treat paragraph 8‑155(2)(a) as having been repealed.
Note: As a result of subsections (2) and (3), Divisions 2 and 3 are applied separately in relation to MOCEs.

Joint Ventures
 (4) In applying Divisions 2, 3 and 4, treat the purposes mentioned in subsection 6‑75(3) (Joint Ventures) as including the purposes of this Part.
Note: As a result of this subsection, Divisions 2, 3 and 4 are applied separately to a Joint Venture and its JV Subsidiaries (which are treated as a separate MNE Group because of section 6‑75).

Investment Entities
 (5) In applying Divisions 3 and 4:
 (a) treat the purposes mentioned in subsection 7‑100(1) (Investment Entities treated as only Constituent Entities of the MNE Group) as including the purposes of this Part; and
 (b) treat the purposes mentioned in subsection 7‑115(1) (Investment Entities treated as not being Constituent Entities of the MNE Group) as including the purposes of this Part.
Note 1: As a result of this subsection, this Part