Section 183

The Adjusted Covered Taxes and GloBE Income or Loss of members of a Minority-Owned Subgroup are excluded from the determination of the remainder of the Effective Tax Rate of the Multinational Enterprise Group in subsections 174(1) to (3)

and Net GloBE Income in subsection 174(4).

The Effective Tax Rate and Multinational Top-up Tax of a Minority-Owned Constituent Entity that is not a member of a Minority-Owned Subgroup is computed on an entity basis in accordance with Chapters 5 to 10 of this Part.

The Adjusted Covered Taxes and GloBE Income or

Loss of the Minority-Owned Constituent Entity are excluded from the determination of the remainder of the Multinational

Enterprise Group’s Effective Tax Rate in subsections 174(1)

to (3) and Net GloBE Income in subsection 174(4).

Subsection (4) does not apply if the Minority-Owned

Constituent Entity is an Investment Entity.

A Minority-Owned Constituent Entity whose Controlling

Interests are held, directly or indirectly, by a Minority-Owned

Parent Entity is a Minority-Owned Subsidiary.

Finance (No. 2)

For the purposes of this section—

“Minority-Owned Parent Entity” means a Minority-Owned

Constituent Entity that holds, directly or indirectly, the

Controlling Interests of another Minority-Owned Constituent

Entity, except where the Controlling Interests of the first-mentioned Entity are held, directly or indirectly, by another Minority-Owned Constituent Entity;

“Minority-Owned Subgroup” means a Minority-Owned

Parent Entity and its Minority-Owned Subsidiaries.