Article 24 - Consolidation Adjustments

On behalf of an Ultimate Parent Entity located in the Kingdom, the Filing Constituent Entity may elect to apply its consolidated accounting treatment to eliminate income, expenses, gains and losses from transactions between Constituent Entities that are located in the Kingdom and included in a tax consolidation group, for the purposes of determining the Constituent Entity Income or Loss of such Constituent Entities.

Adjustments shall be made to the Constituent Entity Income or Loss of any Constituent Entities to which the election under Paragraph A of this Article applies, for the Fiscal Year in respect of which the election is made or revoked so that no items are taken into account more than once or omitted as a result of the election.

The election referred to in Paragraph A of this Article is a Five-Year Election which can be made in accordance with Article 20 of the Law.