‘Flow-through entity’ means an entity that is considered as a fiscally transparent entity with respect to its income, expenditure, profit or loss in the jurisdiction where it was created and which is not tax resident and subject to a covered tax on its income or profit in another jurisdiction;

For the purpose of this definition, a fiscally transparent entity means an entity whose income, expenditure, profit or loss is treated by the laws of a jurisdiction in the same manner as if it were derived or incurred directly by the owner of that entity;

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