Section I Defined Terms
1. The term "Group" means a collection of enterprises related through ownership or control such that it is either required to prepare Consolidated Financial Statements for financial reporting purposes under applicable accounting principles or would be so required if equity interests in any of the enterprises were traded on a public securities exchange.
2. The term "Enterprise" means any form of conducting business by any person referred to in points (b), (c) and (d) of Article 3, point 11.
3. The term "MNE Group" means any Group that includes two or more enterprises the tax residence for which is in different jurisdictions, or includes an enterprise that is resident for tax purposes in one jurisdiction and is subject to tax with respect to the business carried out through a permanent establishment in another jurisdiction, and is not an Excluded MNE Group.
4. The term "Excluded MNE Group" means, with respect to any Fiscal Year of the Group, a Group having total c
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