automatic exchangemeans, In the context of Articles 8(3a), 8(7a) and 21(2) and Article 25(2) and (3), any capitalised term shall have the meaning that it has under the corresponding definitions set out in Annex I.
Consolidated Financial Statementsmeans the financial statements of an MNE Group in which the assets, liabilities, income, expenses and cash flows of the Ultimate Parent Entity and the Constituent Entities are presented as those of a single economic entity.
Constituent Entitymeans any of the following:
Enterprisemeans any form of conducting business by any person referred to in points (b), (c) and (d) of Article 3, point 11.
Excluded MNE Groupmeans, with respect to any Fiscal Year of the Group, a Group having total consolidated group revenue of less than EUR 750000000 or an amount in local currency approximately equivalent to EUR 750000000 as of January 2015 during the Fiscal Year immediately preceding the Reporting Fiscal Year as reflected in its Consolidated Financial Statements for such preceding Fiscal Year.
Fiscal Yearmeans an annual accounting period with respect to which the Ultimate Parent Entity of the MNE Group prepares its financial statements.
Groupmeans 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.
International Agreementmeans the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, any bilateral or multilateral tax convention, or any tax information exchange agreement to which the Member State is a party, and that by its terms provides legal authority for the exchange of tax information between jurisdictions, including automatic exchange of such information.
Qualifying Competent Authority Agreementmeans an agreement that is between authorised representatives of an EU Member State and a non-Union jurisdiction that are parties to an International Agreement and that requires the automatic exchange of country-by-country reports between the party jurisdictions.
Reporting Entitymeans the Constituent Entity that is required to file a country-by-country report conforming to the requirements in Article 8aa(3) in its jurisdiction of tax residence on behalf of the MNE Group.
Reporting Fiscal Yearmeans that Fiscal Year the financial and operational results of which are reflected in the country-by-country report referred to in Article 8aa(3).
Surrogate Parent Entitymeans one Constituent Entity of the MNE Group that has been appointed by such MNE Group, as a sole substitute for the Ultimate Parent Entity, to file the country-by-country report in that Constituent Entity's jurisdiction of tax residence, on behalf of such MNE Group, when one or more of the conditions set out in point (b) of the first paragraph of point 1 of Section II apply.
Ultimate Parent Entitymeans a Constituent Entity of an MNE Group that meets the following criteria: