1‑20 Excluded Entities1‑20 Excluded Entities

1‑20 Excluded Entities

(1) For the purposes of paragraph 20(1)(h) of the Act, the following Entities are prescribed: (a) an Excluded Exempt Income Entity; (b) an Excluded Non‑Profit Subsidiary. (2) An Entity is an Excluded Exempt Income Entity if: (a) at least 85% of the value of the Entity is owned (directly or through a chain of Excluded Entities) by one or more of the following (other than a Pension Services Entity): (i) an Excluded Entity under paragraph 20(1)(a), (b), (c), (d), (e) or (f) of the Act; (ii) if the Entity is an Ultimate Parent Entity—an Investment Fund or a Real Estate Investment Vehicle; and (b) 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 section 3‑20 or 3‑30 of this instrument. (3) An Entity is an Excluded Non‑Profit Subsidiary if: (a) 100% of the value of the Entity is owned (directly or indirectly) by one or more Non‑profit Organisations; and (b) the sum of the revenue of all Group Entities of the MNE Group of which the Entity is a Group Entity (other than such revenue as is attributable to a Group Entity of the MNE Group that is a Non‑profit Organisation, an Excluded Service Entity or an Excluded Exempt Income Entity): (i) does not exceed the MNE Group’s GloBE Threshold for the Fiscal Year; and (ii) is less than 25% of the total revenue of the MNE Group.