Part 3Multinational top-up tax

Chapter 10Definitions etc

Meaning of “entity” etc

231Meaning of entity

1

In this Part “entity” means—

a

a company,

b

a partnership,

c

a trust, or

d

any other arrangement that results in the preparation of separate financial accounts in respect of the activities carried out under the arrangement.

2

An entity which is, or is part of, a national, regional or local government is not to be regarded as an entity for the purposes of this Part.

3

Sections 232 to 238 make further provision about entities including provision—

a

treating permanent establishments as entities,

b

defining various particular types of entities, and

c

about when entities are “tax transparent”.