Article 23 Bis ^[G29]

In applying the provisions of this Chapter, the Executive Regulations, and the decisions issued in implementation thereof, the following terms shall have the meanings set out opposite each of them:

Inclusive Framework : The Inclusive Framework of the Organisation for Economic Co-operation and Development / Group of Twenty on Base Erosion and Profit Shifting.

Global Anti-Base Erosion (GloBE) Model Rules : The rules developed by the Inclusive Framework.

Commentary : The Commentary on the GloBE Model Rules, as developed by the Inclusive Framework.

Agreed Administrative Guidance : The guidance on the interpretation or administration of the GloBE Model Rules, as developed by the Inclusive Framework.

Income Inclusion Rule (IIR) : The rule set forth in Article 2.1 of the GloBE Model Rules.

Domestic Minimum Top-up Tax : A tax calculated based on the excess profits of domestic constituent entities in a manner consistent with the GloBE Model Rules, which brings the domestic tax liability on domestic excess profits up to (15%).

Multinational Enterprise (MNE) Groups : The groups defined in Article 1.2 of the GloBE Model Rules.

Constituent Entities : The entities defined in Article 1.3 of the GloBE Model Rules.

Safe Harbours : Any measures developed by the Inclusive Framework to simplify and reduce the administrative burdens on MNE Groups arising from the application of the GloBE Model Rules.