Vorlage
Vernehmlassung 2015/57: Genehmigung eines Protokolls zur Änderung des Zinsbesteuerungsabkommens zwischen der Schweiz und der EU · 102 Seiten
Fedlex · Vorlage · Seite 54Fedlex · Vorlage
(iii) otherwise investing, administering, or managing Financial Assets or money on behalf of other persons;
or
(b) the gross income of which is primarily attributable to investing, reinvesting, or trading
in Financial Assets, if the Entity is managed by another Entity that is a Depository Institution, a Custodial Institution, a Specified Insurance Company, or an Investment Entity described in subparagraph A(6)(a).
An Entity is treated as primarily conducting as a business one or more of the activities described in subparagraph A(6)(a), or an Entity's gross income is primarily attributable to investing, reinvesting, or trading in Financial Assets for the purposes of subparagraph
A(6)(b), if the Entity's gross income attributable to the relevant activities equals or
exceeds 50 % of the Entity's gross income during the shorter of: (i) the three-year period ending on 31 December of the year preceding the year in which the determination is made; or (ii) the period during which the Entity has been in existence. The term "Investment Entity" does not include an Entity that is an Active NFE because that Entity meets any of the criteria in subparagraphs D(9)(d) to (g).
This paragraph shall be interpreted in a manner consistent with similar language set forth in the definition of "financial institution" in the Financial Action Task Force Recommendations.
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