Document ID: chunk:federal_register_of_legislation:F2024L01740:reg:10:p6
Version: federal_register_of_legislation:F2024L01740
Segment Type: reg
Provision Reference: reg 10 (pt 6/10)
Character Range: 364431–367201

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 a result of an Ownership Interest in a Hybrid Entity.
Payroll Carve‑out Amount: see subsection 5‑55(1).
Portfolio Shareholding: see subsection 3‑25(4).
Profit (Loss) before Income Tax: see section 8‑30.
Qualified Ancillary International Shipping Income: see subsection 3‑230(1).
Qualified CbC Report: see section 8‑35.
qualified debt release amount: see subsection 3‑85(1).
Qualified Domestic Minimum Top‑up Tax means a Tax that is:
 (a) imposed under a law of a jurisdiction; and
 (b) specified in a determination under paragraph 10‑15(b).
Qualified Financial Statements: see section 8‑70.
Qualified IIR means a Tax that is:
 (a) imposed under a law of a jurisdiction; and
 (b) specified in a determination under paragraph 10‑15(a).
Qualified Imputation Tax means a Covered Tax imposed by a jurisdiction (the imposing jurisdiction) and accrued or paid by a Constituent Entity of a Group that is refundable or creditable to the beneficial owner of a dividend distributed by the Constituent Entity (or, in the case of a Covered Tax accrued or paid by a Permanent Establishment, a dividend distributed by the Main Entity), to the extent that any of the following apply:
 (a) the refund is payable, or the credit is provided, under a foreign tax credit regime, by a jurisdiction other than the imposing jurisdiction;
 (b) the beneficial owner is subject to tax on the dividend on a current basis, under the domestic law of the imposing jurisdiction, at a nominal rate that equals or exceeds the Minimum Rate;
 (c) the beneficial owner is an individual who is:
 (i) a tax resident in the imposing jurisdiction; and
 (ii) subject to tax on the dividends as ordinary income;
 (d) if the dividends are received in connection with a pension fund business and subject to tax in a similar manner as a dividend received by a Pension Fund—the refund is payable, or the credit is provided, by a jurisdiction (the benefit jurisdiction) to an Entity that is any of the following:
 (i) a Governmental Entity;
 (ii) an International Organisation;
 (iii) a Non‑profit Organisation that is created and managed in the benefit jurisdiction;
 (iv) a Pension Fund that is created and managed in the benefit jurisdiction;
 (v) an Investment Entity that is not a Group Entity of the Group and is created and regulated in the benefit jurisdiction;
 (vi) a life insurance company that is located in the benefit jurisdiction.
Qualified Refundable Tax Credit: see subsections 3‑125(1) and (2).
Qualified UTPR means a Tax that is:
 (a) imposed under a law of a jurisdiction;