Pillar Two Of The Inclusive Framework On BEPS

A.THE GROUP AND ITS UNITS

1. Definitions of MNE Group

a) Basic definition of MNE Group

1.001 Article 1.2 of the Model Rules establishes the definitions of MNE Group and Group. The first definition of MNE Group is set forth in Article 1.2.1, according to which an MNE Group means any Group that includes at least one Entity or Permanent Establishment (PE) that is not located in the jurisdiction of the Ultimate Parent Entity (UPE). This definition contains some terms requiring reference to other provisions of the Model Rules, such as Group (defined in Article 1.2.2), Entity and PE (supra 1.A.1(b)) (both defined in Article 10.1), as well as UPE (defined in Article 1.4) (infra 1.A.2); these terms will be defined in detail below. For the sake of clarity, it is worth mentioning that according to Article 10.1 the term Entity means: (a) any legal person (other than a natural person) or (b) an arrangement that prepares separate financial accounts, such as a partnership