1 An entity carrying on passive holding business only holds shares or other forms of equity, which are not actively managed. The ownership of any other asset (such as bonds, government securities, real property) will generally take the entity outside of the definition of holding business.
2 “Parent” refers to holding, directly or indirectly, 75% or more of the shares or votes of an entity.
3 In our view, a passive holding business that has not received any dividends or sold any equity during the relevant period likely has a gross income of zero. For a holding business, the “type” of income is typically dividends or capital gains.
3 An MNE Group is a collection of enterprises related through ownership or control with annual consolidated group revenue of not less than €750 million.
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