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SCHEDULES

SCHEDULE 19Large businesses: tax strategies and sanctions

PART 1Interpretation

“Group” and related expressions

7(1)“MNE Group” has the same meaning (subject to sub-paragraph (2) below) as in the OECD Model Legislation in the OECD Country-by-Country Reporting Implementation Package as contained in the OECD’s Guidance on Transfer Pricing Documentation and Country-by-Country Reporting published in 2014.

(2)Paragraph (ii) (excluded MNE Group) of the Implementation Package is not part of the definition applied by sub-paragraph (1) above for the purposes of this Schedule.

(3)In sub-paragraph (1) “OECD” means the Organisation for Economic Co-operation and Development.