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.