Article 44 - Separate Computation for Joint Ventures and Joint Venture Subsidiaries

The Effective Tax Rate for Joint Ventures and Joint Venture Subsidiaries of a Multinational Enterprise Group shall be calculated as if they were Constituent Entities of a separate Multinational Enterprise Group and the Joint Venture was the Ultimate Parent Entity of that Group.

In computing a single Effective Tax Rate for a Joint Venture and its Joint Venture Subsidiaries, the Adjusted Covered Tax and Constituent Entity Income or Loss for each Joint Venture or Joint Venture Subsidiary shall be aggregated.