Top-up Tax Law for Multinational Enterprise Groups

Top-up Tax Law for Multinational Enterprise GroupsArticle 6

Top-up Tax Law · Qualified Income Inclusion Rule

Article 5 of this Law does not apply where a Qualified Income Inclusion Rule is required to be applied for the Financial Year in respect of either of the following: 1. The Ultimate Parent Entity of a Multinational Enterprise Group. 2. Another Intermediate Parent Entity that directly or indirectly owns a controlling interest in the Intermediate Parent Entity.

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