Section 169 Certain non tax resident entities to be treated as flow-through entities

is not tax resident in any territory,

is not subject to covered taxes,

does not have a place of business in the territory where it is created, and

is not regarded as tax transparent in the territory in which it is created.

it is F2regarded as tax transparent in the territory in which F3holders of direct ownership interests in the member are located, and

its income, expenditure, profits and losses are not attributable to a permanent establishment.