Global Minimum Tax Act — G-3.3 2
t is held by one or more entities each of which (i) is a group entity in respect of the particular entity, and (ii) is subject to a regulatory regime, in the jurisdiction in which it is established or managed, that is specific to entities engaged in the business of negotiating and entering into contracts of insurance or annuity or in activities ancillary to that business. ( entité d’investissement d’assurance ) intermediate parent entity means a constituent entity of an MNE group (other than an ultimate parent entity, partially-owned parent entity, permanent establishment, investment entity or insurance investment entity) that holds, directly or indirectly, an ownership interest in another constituent entity of the MNE group. ( entité mère intermédiaire ) international organization means any intergovernmental or supranational organization, or an entity that acts for, is part of or is wholly owned by that organization, if (a) the organization is comprised primarily of governments; (b) it has in effect a headquarters agreement or substantially similar agreement, such as arrangements for privileges or immunities in respect of its offices or establishments, with the jurisdiction in which it is established; and (c) law or its governing documents prevent its income inuring to the benefit of private persons. ( organisation internationale ) international shipping means the transportation of passengers or cargo by ship in international traffic. ( transport maritime international ) international traffic means any transport by ship, except when the ship is operated solely between places within a single jurisdiction. ( trafic international ) intragroup financing arrangement means any arrangement between two or more group entities of an MNE group under which a high-tax counterparty directly or indirectly provides credit to or otherwise makes an investment in a low-tax entity. ( accord de financement intragroupe ) investment entity , for a fiscal year, means (a) an entity that is an investment fund for all or substantially all of the fiscal year; (b) an entity that is a real estate investment vehicle for all or substantially all of the fiscal year; (c) a particular entity, if (i) for all or substantially all of the fiscal year ownership interests in the particular entity having a fair market value equal to at least 95% of the fair market value of all ownership interests in the particular entity are held directly, or indirectly through one or more other entities that are investment funds or real estate investment vehicles, by one or more entities that are investment funds or real estate investment vehicles, and (ii) all or substantially all the activities of the particular entity during the fiscal year consist of holding assets or investing funds for the benefit of any of the investment funds or real estate investment vehicles referred to in subparagraph (i); or (d) a particular entity, if (i) for all or substantially all of the fiscal year ownership interests in the particular entity having a fair market value equal to at least 85% of the fair market value of all ownership interests in the particular entity are held directly, or indirectly through one or more other entities that are investment funds or real estate investment vehicles, by one or more entities that are investment funds or real estate investment vehicles, and (ii) all or substantially all the financial accounting income of the particular entity is comprised of excluded dividends or excluded equity gains or losses. ( entité d’investissement ) investment fund means an entity (a) that is primarily designed or established to (i) pool assets (which may be financial or non-financial) from a number of investors, at least some of which are not connected, and (ii) generate investment income or gains, or protect against a specific or general event or outcome; (b) that invests in accordance with a defined investment policy; (c) that allows investors to reduce transaction, research and an