Section 183
Minority-Owned Constituent Entity
The computation of the Effective Tax Rate and
Multinational Top-up Tax for a jurisdiction in accordance with Chapters 5 to 10 of this Part with respect to members of a Minority-Owned Subgroup shall apply as if they were a separate Multinational Enterprise Group.
(2)
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).
(3)
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.
(4)
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).
(5)
Subsection (4) does not apply if the Minority-Owned
Constituent Entity is an Investment Entity.
(6)
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)
(7)
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.