Multinational Top-up Tax and Domestic Top-up Tax

MTT17010 - Scope: Determining ownership of entities: Overview

A number of provisions in the MTT rules require the ownership of entities to be determined. This includes provisions relating to definitions of types of entity, the calculation of top-up amounts, and the attribution of top-up amounts to responsible members for chargeability purposes.

In some cases, it is necessary to determine whether one entity holds a direct or indirect ownership interest, or a controlling interest, in another (see MTT17030).

It may be necessary to calculate the exact direct or indirect ownership interest held in an entity (see MTT17040). This calculation will differ depending on whether you are looking at the interest held in the entity by a specific entity or individual (see MTT17050), or by a specific class of entities (see MTT17060).

A special rule applies when considering the percentage ownership interest held by excluded entities (see MTT17070).

Where the ownership interest changes, a special rule applies (see MTT17020).