Article 1 provides essential definitions for the administration of the Domestic Minimum Top-Up Tax in Bahrain. Key terms include 'Multinational Enterprise Group', referring to groups with entities in multiple jurisdictions, and 'Constituent Entity', which defines the taxable units within such groups. It identifies the 'Ultimate Parent Entity' as the primary controlling interest holder, excluding Sovereign Wealth Funds. Furthermore, it defines 'Effective Tax Rate' and sets the 'Minimum Rate' at fifteen percent. These definitions align with the OECD Pillar Two Model Rules, ensuring that financial accounting standards and jurisdictional locations are clearly established for MNE compliance within the Kingdom's tax framework.