160. Multinational Top-up Tax

Terms defined in s 157

• Constituent Entity

  Constituent Entity

  Defined · s 157

  “Constituent Entity” means— (a) any Entity that is included in a Group; or (b) any Permanent Establishment of a Main Entity that is within paragraph (a) and which is treated as separate from the Main Entity and any other Permanent Establishment of that Main Entity, but does not include an Excluded Entity;

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• Financial Year

  Financial Year

  Defined · s 157

  “Financial Year” means an accounting period with respect to which the Ultimate Parent Entity of the Multinational Enterprise Group prepares its Consolidated Financial Statements and in the case of Consolidated Financial Statements as defined in paragraph (d) of the definition of “Consolidated Financial Statements”, Financial Year means the calendar year;

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• Multinational Enterprise Group

  Multinational Enterprise Group

  Defined · s 157

  “Multinational Enterprise Group” means any Group that includes at least one Entity or Permanent Establishment that is not located in the jurisdiction of the Ultimate Parent Entity; Finance (No. 2)

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• Multinational Top-up Tax

  Multinational Top-up Tax

  Defined · s 157

  “Multinational Top-up Tax” means tax computed for the jurisdiction or Constituent Entity in accordance with sections 175 to 179;

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• Tax

  Tax

  Defined · s 157

  “Tax” means a compulsory unrequited payment to General Government;

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• Ultimate Parent Entity

  Ultimate Parent Entity

  Defined · s 157

  “Ultimate Parent Entity” means either— (a) an Entity that— (i) owns directly or indirectly a Controlling Interest in any other Entity; and (ii) is not owned, with a Controlling Interest, directly or indirectly by another Entity; or (b) the Main Entity of a Group that is located in one jurisdiction and has one or more Permanent Establishments located in other jurisdictions provided that the Entity is not a part of another Group;

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