‘Parent entity’ means an ultimate parent entity, which is not an excluded entity, an intermediate parent entity, or a partially-owned parent entity;

‘Ultimate parent entity (UPE)’ means:

(a)   an entity that owns, directly or indirectly, a controlling interest in any other entity and that is not owned, directly or indirectly, by another entity with a controlling interest in it; or

(b)   a main entity;

‘Intermediate parent entity’ means a constituent entity that owns, directly or indirectly, an ownership interest in another constituent entity in the same MNE group and that does not qualify as an ultimate parent entity, a partially-owned parent entity, a permanent establishment or an investment entity;

‘Partially-owned parent entity (POPE)’ means a constituent entity that owns, directly or indirectly, an ownership interest in another constituent entity of the same MNE group, more than 20 % of its ownership interest in its profits is held, directly or indirectly, by persons that are not constituent entities of the MNE group and that does not qualify as an ultimate parent entity, a permanent establishment or an investment entity;

‘Controlling interest’ means an ownership interest in an entity whereby the interest holder is required, or would have been required, to consolidate the assets, liabilities, income, expenses and cash flows of the entity on a line-by-line basis, in accordance with an acceptable financial accounting standard;

‘Ownership interest’ means any rights to the profits, capital or reserves of an entity, or a permanent establishment

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