Section 187

Chapters 5 to 10 of this Part shall apply for the purpose of computing any Multinational Top-up

Tax of the Joint Venture and its Joint Venture

Subsidiaries as if they were Constituent Entities of a separate Multinational Enterprise Group and as if the Joint Venture was the Ultimate Parent Entity of that Group;

a Parent Entity that holds directly or indirectly

Ownership Interests in the Joint Venture or a Joint

Venture Subsidiary shall apply the Income Inclusion

Rule with respect to its Allocable Share of the

Multinational Top-up Tax of a member of the Joint

Venture Group in accordance with Chapter 4 of this

Part; and

the Joint Venture Group Top-up Tax shall be reduced by each Parent Entity’s Allocable Share of the

Multinational Top-up Tax of each member of the

Joint Venture Group that is brought into charge under a Qualified Income Inclusion Rule under paragraph (b).

A Permanent Establishment whose Main Entity is the

Joint Venture or a Joint Venture Subsidiary shall be treated as a separate Joint Venture Subsidiary.

For the purposes of this section, “Joint Venture Group

Top-up Tax” means the Ultimate Parent Entity’s Allocable

Share of the Multinational Top-up Tax of all members of the Joint Venture Group.

Act 851

Multi-Parented Multinational Enterprise Groups