Akta Kewangan (No. 2) 2023 · Updated to 29 Dec 2023 · Chapter 8
187. Joint Ventures
Feedback & supportFor each Financial Year, this Part shall apply to a Joint Venture and its Joint Venture Subsidiaries in the following manner:
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
Kewangan (No. 2)
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.