Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p7
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 18202–21109

10‑50 Deemed Flow‑through Entity and Tax Transparent Entity
10‑55 Meaning of Hybrid Entity
Part 10‑3—Location of dual‑located entities
10‑60 Dual‑located entities
10‑65 Dual‑located Parent Entity located in non‑IIR jurisdiction

Chapter 1—Preliminary etc

Part 1‑1—Preliminary

1‑5  Name
  This instrument is the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.

1‑10  Commencement
 (1) Each provision of this instrument specified in column 1 of the table commences, or is taken to have commenced, in accordance with column 2 of the table. Any other statement in column 2 has effect according to its terms.

Commencement information
Column 1                          Column 2                                      Column 3
Provisions                        Commencement                                  Date/Details
1.  The whole of this instrument  The day after this instrument is registered.  24 December 2024

Note: This table relates only to the provisions of this instrument as originally made. It will not be amended to deal with any later amendments of this instrument.
 (2) Any information in column 3 of the table is not part of this instrument. Information may be inserted in this column, or information in it may be edited, in any published version of this instrument.

1‑15  Authority
  This instrument is made under the Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024.
Note: This instrument applies generally in relation to Fiscal Years starting on or after 1 January 2024: see subsection 5(1) of the Act. However, to the extent that this instrument applies to Australian UTPR Tax, it applies in relation to Fiscal Years starting on or after 1 January 2025: see subsection 5(2) of the Act.

Part 1‑2—Excluded Entities

1‑20  Excluded Entities
 (1) For the purposes of paragraph 20(1)(h) of the Act, the following Entities are prescribed:
 (a) an Excluded Exempt Income Entity;
 (b) an Excluded Non‑Profit Subsidiary.
 (2) An Entity is an Excluded Exempt Income Entity if:
 (a) at least 85% of the value of the Entity is owned (directly or through a chain of Excluded Entities) by one or more of the following (other than a Pension Services Entity):
 (i) an Excluded Entity under paragraph 20(1)(a), (b), (c), (d), (e) or (f) of the Act;
 (ii) if the Entity is an Ultimate Parent Entity—an Investment Fund or a Real Estate Investment Vehicle; and
 (b) substantially all of the Entity's income is Excluded Dividends or Excluded Equity Gain or Loss that is excluded from the computation of GloBE Income or Loss in accordance with section 3‑20 or 3‑30 of this instrument.
 (3) An Entity is an Excluded Non‑Profit Subsidiary if:
 (a) 100% of the value of the Entity is owned (directly or indirectly) by one or more Non‑profit Organisations; and
 (b) the sum of the revenue of all Group Entities of the MNE Group of which the Entity is a Group Entity (other