Document ID: chunk:federal_register_of_legislation:F2024L01740:reg:10:p2
Version: federal_register_of_legislation:F2024L01740
Segment Type: reg
Provision Reference: reg 10 (pt 2/10)
Character Range: 353509–356466

Jurisdiction of an MNE Group is the jurisdiction where the MNE Group has the highest total value of tangible assets for the first Fiscal Year starting on or after 1 January 2024 for which the MNE Group is an Applicable MNE Group.
 (2) For the purposes of subsection (1), the MNE Group's total value of tangible assets in a jurisdiction for a Fiscal Year is the sum of the Net Book Value of Tangible Assets for the Fiscal Year of each of the Constituent Entities of the MNE Group that are located in the jurisdiction.
 (3) For the purposes of subsection (2), disregard a Constituent Entity of the MNE Group that is an Investment Entity.
 (4) For the purpose of this section, treat an Insurance Investment Entity as if it were an Investment Entity.

Chapter 10—Definitions

Part 10‑1—Defined terms

10‑5  Definitions
Note: A number of expressions used in this instrument are defined in the Act, including the following:
(a) Annual Election;
(b) Constituent Entity;
(c) Entity;
(d) Fiscal Year;
(e) Five‑Year Election;
(f) Main Entity;
(g) MNE Group;
(h) Ownership Interest;
(i) Permanent Establishment;
(j) Tax Treaty.
  In this instrument:
accounting functional currency: see subsection 3‑60(2).
Accrued Current Covered Tax Expense: see section 4‑10.
Act means the Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024.
Additional Current Top‑up Tax: see subsection 4‑30(3), paragraph 5‑95(3)(b) and paragraph 7‑75(2)(c).
Additional Tier One Capital: see subsection 3‑210(2).
Additions to Covered Taxes: see section 4‑15.
Adjusted Covered Taxes: see section 4‑5.
Aggregate Asset Gain: see section 3‑170.
Allocable GloBE Income or Loss: see subsection 7‑110(1).
Allocable Share: see section 2‑10.
Ancillary International Shipping Activity: see subsection 3‑230(3).
Ancillary International Shipping Income: see subsection 3‑230(2).
Ancillary International Shipping Income Costs: see subsection 3‑230(4).
Ancillary International Shipping Income Revenue: see subsection 3‑230(3).
Arm's Length Principle: see section 3‑105.
Average GloBE Income or Loss: see paragraph 5‑110(1)(b).
Average GloBE Revenue: see paragraph 5‑110(1)(a).
Blended CFC Tax Regime: see section 4‑60.
CbCR Resident: see section 8‑65.
Constituent Entity‑owner: if a Constituent Entity of an MNE Group holds an Ownership Interest in another Constituent Entity of the MNE Group, the Constituent Entity is a Constituent Entity‑owner of the other Constituent Entity.
Controlled Foreign Company Tax Regime means a set of tax rules (other than an IIR or any Tax equivalent to an IIR) under which an Entity located in a jurisdiction (the owner) that holds an Ownership Interest in another Entity located in another jurisdiction (the CFC) is subject to current taxation on its share of part or all of the income earned by the CFC, irrespective of whether that income is distributed currently to the owner.
Cooperative means an Entity that:
 (a) collectively markets or acquires goods or