An unincorporated enterprise in the host country which is one of the following: (i) a permanent establishment or office of the foreign investor; (ii) an unincorporated partnership or joint venture (defined below) between the foreign direct investor and one or more third parties; (iii) land, structures (except structures owned by government entities), and/or immovable equipment and objects directly owned by a foreign resident; (iv) mobile equipment (such as ships, aircraft, gas or oil-drilling rigs) operating within a country other than that of the foreign investor for at least one year.

Under the fully consolidated system:


Enterprise N

  • A is a subsidiary of N;
  • B is indirectly a subsidiary of N;
  • C is an associate of B and hence of N, provided that B has an effective voice in the management of C;
  • D is a subsidiary of N and an affiliate of A;
  • L is a branch of D and hence of N.

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