Surrogate Parent Entity definition

Surrogate Parent Entity means one Constituent Entity of the MNE Group that has been appointed by such MNE Group, as a sole substitute for the Ultimate Parent Entity, to file the country-by-country report in that Constituent Entity's jurisdiction of tax residence, on behalf of such MNE Group, when one or more of the conditions set out in point b) of point 1 of Section II apply.
Surrogate Parent Entity means one Constituent Entity of the MNE Group that has been appointed by the MNE Group as a sole substitute for the Ultimate Parent Entity to file the Country-by-Country Report in that Constituent Entity’s jurisdiction of tax residence on behalf of the said MNE Group when one or more of the conditions set out in regulation 4(2)(b) applies;
Surrogate Parent Entity means one constituent entity of the MNE Group that is appointed by such group, as a sole substitute for the ultimate parent entity, to file the CbC report in its jurisdiction of tax residence on behalf of such MNE Group.

Examples of Surrogate Parent Entity in a sentence

  • The appointment of the Surrogate Parent Entity is on the premise that certain conditions are met; 3 http://www.oecd.org/tax/automatic-exchange/common-reporting-standard/ this however depends on whether the entity is resident in an EU Member State or in a non-EU Member State.

  • A constituent entity of the group which is not the UPE nor the Surrogate Parent Entity and which is required to file the CbC Report under the secondary reporting mechanism.

  • We are not suggesting that an irregularity has occurred or is likely to occur.

  • In addition, each domestic enterprise (“Constituent Entity”) that is neither Ultimate Parent Entity nor Surrogate Parent Entity is obliged to file a CbCR if the Federal Central Tax Office [Bundeszentralamt für Steuern – “BZSt”] does not receive a country-specific report from a foreign Ultimate Parent Entity.

  • The definition of Qualifying Competent Authority Agreement will be discussed in paragraph 2.6.2. The third and fourth condition concern the notification obligation in the Netherlands, and in the jurisdiction of tax residence of the Surrogate Parent Entity.


More Definitions of Surrogate Parent Entity

Surrogate Parent Entity means any constituent entity of the MNE group that has been designated by such MNE group, in place of the ultimate parent entity, to file the country-by-country reports in the country or territory in which the said constituent entity is resident, on behalf of such MNE group;
Surrogate Parent Entity means one constituent entity of the multinational enterprise group appointed by such group to file the country-by-country report in that constituent entity’s jurisdiction of tax residence, on behalf of the group;
Surrogate Parent Entity means a constituent entity of a reportable group appointed as the sole substitute for the ultimate parent entity to file a CbC return or report on behalf of the group.
Surrogate Parent Entity. Means where the conditions set out in Article 18 of the Bylaws are met, the Constituent Entity of an MNE Group appointed by such MNE Group as the sole substitute for the Ultimate Parent Entity to file the CbC Report in that Constituent Entity’s jurisdiction of tax residence on behalf of such MNE Group.
Surrogate Parent Entity means one constituent entity of the MNE group that has been appointed by such MNE group as a sole substitute for the ultimate parent entity, to file the country by country report in that constituent entity’s jurisdiction of tax residence, on behalf of the MNE group in accordance with section 10P;
Surrogate Parent Entity means one constituent entity of the multi-national enterprise group that is ap- pointed by a multi- national enterprise group as a sole substitute for the ultimate parent entity, to file a country-by-country report in that constituent entity’s State of tax residence, on behalf of the multi-national enterprise group, when one or more of the conditions set out in sub-regulation (5)(b) is applied;
Surrogate Parent Entity means a Constituent Entity of an MNE Group, appointed by the MNE Group, as a sole substitute for the Ultimate Parent Entity, to file the Country-by-Country Report under regulation 3(2);