Division 1 An arrangement that involves deductible cross-border payments made between two or more associated enterprises where at least one of the following conditions occurs:F1

the recipient is not resident for tax purposes in any tax jurisdiction;

although the recipient is resident for tax purposes in a jurisdiction, that jurisdiction either:

1. (i)

   does not impose any corporate tax or imposes corporate tax at the rate of zero or almost zero; or

2. (ii)

   is included in a list of third-country jurisdictions which have been assessed by Member States collectively or within the framework of the OECD as being non-cooperative;

the payment benefits from a full exemption from tax in the jurisdiction where the recipient is resident for tax purposes;

the payment benefits from a preferential tax regime in the jurisdiction where the recipient is resident for tax purposes;