158. Scope of application

Terms defined in s 157

• Entity

  Entity

  Defined · s 157

  “Entity” means— (a) any legal person (other than a natural person); or (b) an arrangement that prepares separate financial accounts, such as a partnership or trust;

  Open s 157
• Excluded Entity

  Excluded Entity

  Defined · s 157

  “Excluded Entity” means— (a) a Governmental Entity; (b) an International Organisation; (c) a Non-profit Organisation; (d) a Pension Fund; (e) an Investment Fund that is an Ultimate Parent Entity; (f) a Real Estate Investment Vehicle that is an Ultimate Parent Entity; or (g) an Entity— (i) where at least ninety-five per cent of the value of the Entity is owned directly or through a chain of Excluded Entities by one or more Excluded Entities referred above other than a Pension Services Entity and where that Entity— (A) operates exclusively or almost exclusively to hold assets or invest funds for the benefit of the Excluded Entity or Entities; or (B) only carries out activities that are ancillary to those carried out by the Excluded Entity or Entities; or (ii) where at least eighty-five per cent of the value of the Entity is owned directly or through a chain of Excluded Entities, by one or more Excluded Entities referred above other than a Pension Services Entity provided that substantially all of the Entity’s income is Excluded Dividends or Excluded Equity Gain or Loss that is excluded from the computation of GloBE Income or Loss in accordance with this Part; Finance (No. 2)

  Open s 157
• Filing Constituent Entity

  Filing Constituent Entity

  Defined · s 157

  “Filing Constituent Entity” means an Entity filing the return in accordance with section 201 or 202;

  Open s 157
• Financial Year

  Financial Year

  Defined · s 157

  “Financial Year” means an accounting period with respect to which the Ultimate Parent Entity of the Multinational Enterprise Group prepares its Consolidated Financial Statements and in the case of Consolidated Financial Statements as defined in paragraph (d) of the definition of “Consolidated Financial Statements”, Financial Year means the calendar year;

  Open s 157
• Five-Year Election

  Five-Year Election

  Defined · s 157

  “Five-Year Election” means an election in the prescribed form made by a Filing Constituent Entity and furnished to the Director General with respect to a Financial Year (hereinafter referred to as the “election year”) that cannot be revoked with respect to the election year or the four succeeding Financial Years and if revoked with respect to a Financial Year (hereinafter referred to as the “revocation year”), a new election cannot be made with respect to the four Financial Years succeeding the revocation year;

  Open s 157
• Multinational Enterprise Group

  Multinational Enterprise Group

  Defined · s 157

  “Multinational Enterprise Group” means any Group that includes at least one Entity or Permanent Establishment that is not located in the jurisdiction of the Ultimate Parent Entity; Finance (No. 2)

  Open s 157
• Ultimate Parent Entity

  Ultimate Parent Entity

  Defined · s 157

  “Ultimate Parent Entity” means either— (a) an Entity that— (i) owns directly or indirectly a Controlling Interest in any other Entity; and (ii) is not owned, with a Controlling Interest, directly or indirectly by another Entity; or (b) the Main Entity of a Group that is located in one jurisdiction and has one or more Permanent Establishments located in other jurisdictions provided that the Entity is not a part of another Group;

  Open s 157