Any term or expression contained in this notice to which a meaning has been assigned in a "tax Act" as defined in section 1 of the Tax Administration Act, 2011, ("the Act") or the Country-by-Country Regulations, has the meaning so assigned unless the context indicates otherwise and the following terms have the following meaning—

"BRS: CbC and Financial Data Reporting"

means the Country-by-Country and Financial Data Reporting external business requirement specification reporting schema;

"Country-by-Country Regulations"

means the regulations for purposes of paragraph (b) of the definition of "international tax standard" in section 1 of the Act promulgated under section 257 of the Act, specifying the changes to the Country-by-Country Reporting Standard for Multinational Enterprises, and published in Government Gazette No. 40516 of 23 December 2016;

"potentially affected transaction"

means an "affected transaction", as defined in section 31 of the Income Tax Act, without regard to paragraph (b) of the definition, but excludes any transaction, operation, scheme, agreement or understanding contemplated in section 31(5), (6) or (7) of the Income Tax Act; and

"ultimate holding company in respect of the Group"

means a person that is a resident and owns directly or indirectly a sufficient interest in one or more other entities within the Group such that it is required to prepare Consolidated Financial Statements under accounting principles generally applied in the Republic or would be so required if its shares were listed shares and there is no other entity within the Group that owns directly or indirectly an interest so described in the person.