INTERNATIONAL TAX PLAZA - Tax transparent entity

Details: Published: 03 February 2022

‘Tax transparent entity’ means:

(a) a flow-through entity that is considered as fiscally transparent in the jurisdiction in which its owner is located.

(b) an entity that is not tax resident and not subject to a covered tax or a qualified domestic top-up tax based on its place of management, place of creation or similar criteria to the extent that, in respect of its income, expenditure, profit or loss:

(i) its owners are located in a jurisdiction that treats the entity as fiscally transparent;

(ii) it does not have a place of business in the jurisdiction where it was created; and

(iii) the income, expenditure, profit or loss is not attributable to a permanent establishment;

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