Part 3Multinational top-up tax

Chapter 10Definitions etc

Meaning of “entity” etc

237Intermediate and partially-owned parent members

1

A member of a multinational group is a partially-owned parent member of that group if—

a

it is not a permanent establishment, investment entity or the ultimate parent,

b

it has (directly or indirectly) an ownership interest in another member of the group, and

c

more than 20% of the ownership interests that represent an entitlement to a share of the profits of the member are held by persons that are not members of the group.

2

A member of a multinational group is an intermediate parent member of the group if—

a

it is not a permanent establishment, investment entity, a partially-owned parent member or the ultimate parent, and

b

it has (directly or indirectly) an ownership interest in another member of the group.