‘Entity’ means any legal person or legal arrangement that prepares separate Financial Accounts.
‘Constituent entity’ means an entity or permanent establishment that is part of an MNE group or a large-scale domestic group.
‘Low-taxed constituent entity’ means:
(a) a constituent entity of an MNE group that is located in a low-tax jurisdiction; or
(b) a stateless constituent entity that, in respect of a fiscal year, has an effective tax rate which is lower than the minimum effective tax rate.
‘Low-tax jurisdiction’ means a Member State or a third country jurisdiction in which, in a given fiscal year, an MNE group has an effective tax rate which is lower than the minimum tax rate.
‘Minimum tax rate’ means fifteen percent (15 %).
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