214 Taxable distribution method election

214  Taxable distribution method election

(1)     The filing member of a multinational group may elect that a member of the group (an “owner”) with direct ownership interests in an investment entity that is a member of the group is to have those interests treated in accordance with this section.

(2)     The filing member may only make such an election if—

(a)     an election under section 213 is not in effect in relation to the owner,

(b)     the owner is not itself an investment entity, and

(c)     the owner can reasonably

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