Treasury Laws Amendment (Multinational - Global and Domestic Minimum Tax) (Consequential) Act 2024 (134 of 2024)

Schedule 1   Amendments

Taxation Administration Act 1953

56   At the end of section 355-25 in Schedule 1

Add:

(3) An entity (the covered entity ) is covered by this subsection in relation to *protected information that relates to another entity (the primary entity ) if:

(a) all of the following subparagraphs apply:

(i) the primary entity is, or has been, a *Group Entity of an *Applicable MNE Group;

(ii) the covered entity is, or has been, a Group Entity of an Applicable MNE Group;

(iii) the protected information relates to the *Australian GloBE tax affairs of any entity that is, or has been, a Group Entity of the Applicable MNE Group; or

(b) all of the following subparagraphs apply:

(i) the primary entity is, or has been, a *GloBE Joint Venture of an Applicable MNE Group;

(ii) the covered entity is, or has been, a *Globe JV Subsidiary of the GloBE Joint Venture;

(iii) the protected information relates to the Australian GloBE tax affairs of any entity that is, or has been, a Globe JV Subsidiary of the GloBE Joint Venture; or

(c) all of the following subparagraphs apply:

(i) the primary entity is, or has been, a GloBE JV Subsidiary of a GloBE Joint Venture of an Applicable MNE Group;

(ii) the covered entity is, or has been, the GloBE Joint Venture, or another GloBE JV Subsidiary of the GloBE Joint Venture;

(iii) the protected information relates to the Australian GloBE tax affairs of any entity that is, or has been, the GloBE Joint Venture or a GloBE JV Subsidiary of the GloBE Joint Venture; or

(d) all of the following subparagraphs apply:

(i) the primary entity is, or has been, a GloBE Joint Venture of an Applicable MNE Group or a GloBE JV Subsidiary of a GloBE Joint Venture of an Applicable MNE Group;

(ii) the covered entity is, or has been, a Group Entity of the Applicable MNE Group;

(iii) the protected information relates to the Australian GloBE tax affairs of any entity that is, or has been, the GloBE Joint Venture, a Globe JV Subsidiary of the GloBE Joint Venture or a Group Entity of the Applicable MNE Group; or

(e) the covered entity is the *registered tax agent or BAS agent of another covered entity mentioned in paragraph (a), (b), (c) or (d) in relation to the relevant primary entity mentioned in those paragraphs; or

(f) the covered entity is a *legal practitioner:

(i) representing another covered entity mentioned in paragraph (a), (b), (c) or (d) in relation to the affairs of the relevant primary entity mentioned in those paragraphs; and

(ii) representing the other covered entity in relation to the other entity's Australian GloBE tax affairs.