Global Minimum Tax Act — G-3.3 2
e 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 analytical costs or to spread risk collectively; (d) the investors in which have a right to the assets of the entity, or income earned on those assets, based on the respective contributions made by those investors; (e) that is, or whose management is, subject to a regulatory regime (which may include appropriate anti-money laundering and investor protection regulations) in the jurisdiction in which the entity is established or managed; and (f) that is managed by investment management professionals on behalf of its investors. ( fonds de placement ) joint venture , in respect of a particular MNE group (other than a group composed exclusively of excluded entities), means a particular entity (a) whose financial results are reported under the equity method in the consolidated financial statements of the ultimate parent entity of the particular MNE group; (b) of which at least 50% of the ownership interests are held, directly or indirectly, by the ultimate parent entity of the particular MNE group; and (c) that is not (i) the ultimate parent entity of an MNE group, a constituent entity of which, or joint venture in respect of which, is subject to a qualified IIR or qualified UTPR, (ii) an excluded entity described in paragraph 13 (1)(a), (iii) an entity, if (A) all ownership interests in that entity held by group entities in respect of the particular MNE group are held directly by excluded entities described in paragraph 13 (1)(a), and (B) one of the following conditions is met: (I) the entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of its investors, (II) the entity carries out activities that are ancillary to those carried out by any of those group entities, or (III) all or substantially all of the financial accounting income of the entity is excluded dividends or excluded equity gains, or (iv) a joint venture subsidiary of another joint venture. ( coentreprise ) joint venture entity , of a joint venture group, means the joint venture or a joint venture subsidiary of the group. ( entité d’une coentreprise ) joint venture group means a joint venture and its joint venture subsidiaries, if any. ( groupe d’une coentreprise ) joint venture subsidiary , of a joint venture, means an entity (other than the joint venture or an excluded entity) the assets, liabilities, income, expenses and cash flows of which would, because of ownership or control, be included in the consolidated financial statements of the joint venture if the references to “ultimate parent entity” in the definition consolidated financial statements in this subsection were read as references to the “joint venture”. ( filiale d’une coentreprise ) jurisdictional adjusted covered taxes has the same meaning as in subsection 29 (3). ( impôts concernés ajustés juridictionnels ) jurisdictional excess negative tax expense top-up amount has the same meaning as in subsection 31 (4). ( montant complémentaire de la charge d’impôt négative excédentaire juridictionnel ) jurisdictional GloBE income or loss has the same meaning as in subsection 33 (4). ( résultat net GloBE juridictionnel ) jurisdictional GloBE revenue has the same meaning as in subsection 33 (2). ( chiffre d’affaires GloBE juridictionnel ) jurisdictional top-up amount has the same meaning as in subsection 30 (2). ( montant complémentaire juridictionnel ) local tangible asset , in respect of a constituent entity, means real or immovable property situated in the same jurisdiction as the jurisdiction where the constituent entity is located. ( actif corporel local ) local taxation year of an entity means the period for which the accounts of the entity have been ordinarily made up for the purpose of computing the entity’s income for tax purposes in the jurisdiction in which the entity