Regulation 82

Conditions A, B, C, D and E in regulation 80 (as modified by paragraph (2)), and Condition F, are disqualifying conditions for the purposes of regulation 78(3)(b) in relation to an MNE group and a jurisdiction.

Condition C in regulation 80 is modified by replacing any reference to a constituent entity of the MNE group with an investment entity or insurance investment entity of the MNE group.

Condition F is that investment entities or insurance investment entities of an MNE group do not come within the scope of the law of that jurisdiction imposing a qualified domestic minimum top‑up tax.