INTERNATIONAL TAX PLAZA - (Low-taxed) Constituent entities

Details: Published: 01 February 2022

‘Entity’ means any legal person or legal arrangement that prepares separate Financial Accounts.

‘Constituent entity’ means an entity or permanent establishment that is part of an MNE group or a large-scale domestic group.

‘Low-taxed constituent entity’ means:

(a) a constituent entity of an MNE group that is located in a low-tax jurisdiction; or

(b) a stateless constituent entity that, in respect of a fiscal year, has an effective tax rate which is lower than the minimum effective tax rate.

‘Low-tax jurisdiction’ means a Member State or a third country jurisdiction in which, in a given fiscal year, an MNE group has an effective tax rate which is lower than the minimum tax rate.

‘Minimum tax rate’ means fifteen percent (15 %).

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