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Pillar Two: Insurance Investment Entities

Pillar Two: Insurance Investment Entites

Insurance Investment Entities are subject to special treatment under the Pillar Two GloBE Rules. 
 
Article 10.1 of the Model Rules defines an Insurance Investment Entity as an entity that would qualify as an Investment Fund or Real Estate Investment Vehicle but for the fact that it is wholly-owned by an insurance company and established in relation to liabilities under one or more insurance or annuity contracts.
 
An Insurance Investment Entity may be wholly-owned by a single entity, or by a number of entities which are all part of the same MNE Group. However, the owner(s) must be subject to regulation in their residence jurisdiction as an insurance company.
 

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