Entity Types
Constituent Entities (In Scope)
Any entity or PE included in group's consolidated financial statements. Must be consolidated line-by-line. Includes subsidiaries, branches, PEs. Each entity tested for 15% minimum ETR in its jurisdiction.
Excluded Entities (Out of Scope)
Government entities. International organisations. Non-profit organisations. Pension funds. Investment funds (UPE of group). Real estate investment vehicles. Certain conditions must be met for each exclusion.
Special Cases
Joint ventures — separate computation if ≥50% owned. Minority interests — included if consolidated. Flow-through entities — tax allocated to owner. Stateless entities — special rules apply. Multi-parented groups — combined approach.