The Consolidated Revenue Threshold to group mergers and demergers is determined according to the following provisions:
When two or more Groups merge to form a single Group during any of the four Tax Periods preceding the tested Tax Period, the Revenue Threshold for the MNE Group shall be considered met for any Tax Period prior to the merger if the combined revenues included in the CFS of each Group during that period equals or exceeds EUR 750 million (or its equivalent in Kuwaiti Dinar).
When an Entity that is not a member of any Group (the "Target Entity”) merges with an Entity or Group (the "Acquiring Party”) during the tested Tax Period, and neither the Target Entity nor the Acquiring Party had CFSs during any of the four Tax Periods preceding the tested period, the Revenue Threshold for the MNE Group shall be considered met for that Tax Period if the total revenues included in the FS or the CFS of each party during that period equal or exceed EUR 750 million (or its equivalent in Kuwaiti Dinar).
In the case of a demerger of one MNE Group subject to the scope of the law or the GloBE Rules into two or more Groups (each referred to as a "Separate Group”), the Revenue Threshold shall be considered met by the Separate Group as follows:
For the first tested Tax Period (referred to as the "year of demerger”) that ends after the demerger occurred, the Revenue Threshold shall be considered met if the annual revenues of the Separate Group during that period equal or exceed EUR 750 million (or its equivalent in Kuwaiti Dinar).
For the second through fourth Tax Periods ending after the demerger, the Revenue Threshold shall be considered met if the annual revenues of the Separate Group equal or exceed EUR 750 million (or its equivalent in Kuwaiti Dinar) in at least two of the Tax Periods following the year of demerger.