Part 3Multinational top-up tax

Chapter 10Definitions etc

Meaning of “entity” etc

238Tax transparency of entities

An entity is regarded as tax transparent in a territory F1to the extent that the territory treats the income, expenditure, profits F2or losses of the entity, for the purposes of covered taxes, as the income, expenditure, profits F2or losses of the direct owner of the entity in proportion to its interest in the entity.