Part 3Multinational top-up tax
Chapter 10Definitions etc
Ownership of entities
244Calculating percentage ownership interests of a class
1
For the purpose of determining the percentage of ownership interests in an entity (“A”) held by a class of entities (“B”)—
a
ignore any indirect ownership interest required to be ignored as described in subsection (2), and
b
reduce any percentage direct ownership interest required to be reduced in accordance with subsection (3).
2
An indirect ownership interest is to be ignored if—
a
it is an indirect ownership interest held by an entity that is not a member of B, or
b
it is an indirect ownership interest held by a member of B through another entity that is a member of B.
3
Where a member of B holds an indirect ownership interest in A solely through an entity, or entities, that are not members of B, the direct ownership interest from which it is derived is to be reduced by the amount of that indirect ownership interest.
4
This section does not apply—
a
for the purpose of any provision that requires the calculation of direct ownership interests only, or
b
for the purposes of section 127(6)(a) and (7)(a) (whether an entity is 95% or 85% owned by qualifying excluded entities).