For the purposes of this Law, unless the context otherwise requires, the following words and expressions have the meanings set out beside them: 1. Top-up Tax: The Top-up Tax provided for in this Law. 2. Global Anti-Base Erosion Rules (GloBE Rules): The rules and guidance relating to countering base erosion and profit shifting issued by the Organisation for Economic Co-operation and Development. 3. Income Inclusion Rule (IIR): The rules included within the Global Anti-Base Erosion Rules. 4. Entity: Any legal person legally required to prepare separate financial accounts. This does not include units of the State Administrative Apparatus or other public legal persons. 5. Ultimate Parent Entity (UPE): An entity that directly or indirectly owns a controlling interest in any other entity and is not itself directly or indirectly owned by another entity through a controlling interest, or the main entity of a group. 6. Group means: (a) Multiple entities related through ownership or control, whose assets, liabilities, income, expenses and cash flows are either included in the consolidated financial statements of the Ultimate Parent Entity or excluded from those statements on grounds of size or materiality or because the entity is held for sale. (b) An entity located in one jurisdiction that has one permanent establishment, or more than one permanent establishment, located in other jurisdictions, provided that the entity is not part of another group. 7. Multinational Enterprise Group (MNE Group): A group that includes at least one entity or one permanent establishment not located in the jurisdiction of the Ultimate Parent Entity. 8. Constituent Entity means: (a) An entity within a group. (b) A permanent establishment of a main entity. 9. Financial Year: The accounting period for which the Ultimate Parent Entity of a Multinational Enterprise Group prepares consolidated financial statements, or the calendar year where consolidated financial statements are not prepared. 10. Regulation: The Executive Regulation of this Law.
Interpretation and application must be checked against the official Arabic text and the current version.