Part 3Multinational top-up tax
Chapter 9Special provision for investment entities, joint venture groups and minority-owned members
Minority owned members
228Minority owned members
1
For the purposes of this Part, a member of a multinational group is a “minority owned member” if—
a
the ultimate parent holds no more than 30% of the ownership interests in that member, and
b
the member is not an investment entity.
2
If—
a
a minority owned member (“M”) holds (directly or indirectly) ownership interests in another minority owned member, and
b
no other minority owned member holds (directly or indirectly) ownership interests in M,
M is the minority owned parent of a minority subgroup, and the minority owned members in which M has ownership interests are also members of that group.
3
For the purpose of determining the effective tax rate and top-up amounts of members of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to members of that subgroup.
4
For the purposes of determining the effective tax rate and top-up amounts of a minority owned member that is not a member of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to that member.