Part 3Multinational top-up tax

Chapter 10Definitions etc

Ownership of entities

243Calculating percentage ownership interests of a specific entity or individual

1

For the purpose of determining the percentage ownership interests in an entity (“A”) held by a specific entity or individual (“B”)—

a

ignore any indirect ownership interest not held by B, and

b

where B has an indirect ownership interest in A, reduce the direct ownership interest from which it is derived by the amount of that indirect ownership interest.

2

But this section does not apply for the purpose of any provision that requires the calculation of direct ownership interests only.