Article 2 - Charging Provision

2.1 The following Entities shall pay the Top-up Tax for a Fiscal Year:

(a) Constituent Entities located in the UAE during that Fiscal Year, including those that are members of a Minority-owned Subgroup.

(b) Joint Ventures and JV Subsidiaries located in the UAE during that Fiscal Year;

(c) Stateless Constituent Entities created in accordance with the laws of the UAE and that are Reverse Hybrid Entities, with respect to any of their Pillar Two Income or Loss as allocated and computed in accordance with this Decision.

2.2 Notwithstanding Article 2.1:

(a) the Constituent Entities of the Domestic Main Group and a Domestic Minority-owned Subgroup, may appoint a Domestic Designated Filing Entity to pay the Top-up Tax on behalf of the members of their Domestic Groups;

(b) the Joint Venture and JV Subsidiaries of a Domestic JV Group may appoint a Domestic Designated Filing Entity to pay the Top-up Tax on behalf of the members of their Domestic JV Group; and

(c) the Reverse Hybrid Entities referred to in Article 2.1(c), may appoint a Domestic Designated Filing Entity that is a member of the Domestic Main Group or Domestic Minority-owned Subgroup to pay its Top-up Tax.

2.3 An Investment Entity located in the UAE is not subject to the Top-up Tax.