Article 20 distinguishes between 'Annual Elections' and 'Five-Year Elections' that a Filing Constituent Entity can make regarding its tax obligations. An Annual Election applies strictly to a single fiscal year, whereas a Five-Year Election remains in effect for at least five consecutive years and cannot be revoked during that period. If a Five-Year Election is eventually revoked, the entity is barred from making a new election for the following four years. These elections, which must be notified to the Bureau, allow MNEs to choose specific tax treatments, such as safe harbours, in accordance with the OECD Pillar Two administrative framework.