(1) This section applies in relation to the relevant taxpayer, in relation to the DPT tax benefit, if the sum of the following does not exceed $25 million:
(a) the assessable income of the relevant taxpayer for the year of income mentioned in paragraph 177J(1)(a);
(b) the exempt income of the relevant taxpayer for that year of income;
(c) the non - assessable non - exempt income of the relevant taxpayer for that year of income;
(d) the assessable income of each entity covered by subsection (2) for that year of income;
(e) if the DPT tax benefit is a tax benefit mentioned in paragraph 177C(1)(a)--the amount of the DPT tax benefit.
(2) An entity is covered by this subsection if for the year of income mentioned in paragraph 177J(1)(a):
(a) the entity is an associate (within the meaning given by section 318) of the relevant taxpayer; and
(b) both the entity and the relevant taxpayer:
(i) are members of the same global group; and
(ii) are significant global entities because they are members of that group.