223 Adjustments

223 Ìý´¡»åÂá³Ü²õ³Ù³¾±ð²Ô³Ù²õ

(1)     In this section each of the following amounts is a “relevant amountâ€â€”

(a)     the adjusted profits of an investment entity;

(b)     a substance based income exclusion for an investment entity;

(c)     the covered tax balance of an investment entity.

(2)     An external holding adjustment is to be made to each relevant amount if a person that is not a member of the multinational group has ownership interests in the entity and no election under section 213 (tax transparency election) has been made in relation to the entity.

(3)     An election adjustment

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