Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p133
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 333965–336787

a Joint Venture of an MNE Group, or a JV Subsidiary of a Joint Venture of an MNE Group, that is located in the jurisdiction is not required to apply the Qualified Domestic Minimum Top‑up Tax of the jurisdiction for the Fiscal Year in any circumstance (including where liability under the Qualified Domestic Minimum Top‑up Tax in respect of the Joint Venture or the JV Subsidiary is imposed on Constituent Entities of the MNE Group).

Investment Entities not required to apply QDMTT
 (7) This subsection applies if:
 (a) the MNE Group is an MNE Group mentioned in subsection 7‑100(1) (Investment Entities); and
 (b) a Constituent Entity of the MNE Group meets the following conditions:
 (i) it is located in the jurisdiction;
 (ii) it is an Investment Entity or an Insurance Investment Entity; and
 (c) a Constituent Entity of an MNE Group that meets those conditions is not required to apply the Qualified Domestic Minimum Top‑up Tax of the jurisdiction for the Fiscal Year in any circumstance.

Initial phase of international activity year
 (8) This subsection applies if:
 (a) the Qualified Domestic Minimum Top‑up Tax of the jurisdiction provides that it does not apply to an MNE Group and a Fiscal Year in relation to which subsection 9‑40(1) applies; and
 (b) that provision is not limited in application to circumstances where the Constituent Entities of the MNE Group located in the jurisdiction are not subject to a Qualified IIR applied by another jurisdiction; and
 (c) that provision applies to the MNE Group and the Fiscal Year mentioned in subsection (1).

Other specified restrictions
 (9) This subsection applies if:
 (a) the jurisdiction has a Qualified Domestic Minimum Top‑up Tax for a Fiscal Year; and
 (b) the jurisdiction is specified in a determination under subsection 8‑200(2); and
 (c) a determination under subsection (10) of this section specifies the jurisdiction and a restriction of the jurisdiction's Qualified Domestic Minimum Top‑up Tax; and
 (d) the restriction applies to the MNE Group for the Fiscal Year.
 (10) The Minister may, by legislative instrument, make a determination specifying:
 (a) a jurisdiction; and
 (b) a restriction of the jurisdiction's Qualified Domestic Minimum Top‑up Tax.

8‑215  Meaning of OECD Securitisation Entity
 (1) An Entity is a OECD Securitisation Entity if:
 (a) the Entity is a participant in a Securitisation Arrangement; and
 (b) the Entity only carries out activities that facilitate one or more Securitisation Arrangements; and
 (c) the Entity grants security over its assets in favour of its creditors (or the creditors of another OECD Securitisation Entity); and
 (d) the Entity pays out all cash received from its assets to its creditors (or the creditors of another OECD Securitisation Entity), on an annual or more frequent basis, other than: