Article 16 - Initial Phase of International Activity

The tax on the taxpayer will be zero during the initial phase of international activity if it is part of a group of multinational entities that meets the following conditions:

1. It has members in no more than six states or jurisdictions, including the state.

2. The total net book value of tangible assets does not exceed 50 million euros for all entities in all states or jurisdictions, except for the state or jurisdiction where the multinational group owns the highest value of tangible assets when applying the Pillar Two rules to that group for the first time.

3. No ownership shares in the entities located in the state are held by the parent entity that applies income inclusion rules.

The provisions of this Article do not apply to any tax period starting after the expiration of five tax periods from the first day of the first tax period during which the group of multinational entities was subject to rules of Pillar Two.

The executive regulations will define the necessary rules, conditions, and provisions for the application of this Article.