Article 23 Bis

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.