234 Governmental, international and non-profit entities

234  Governmental, international and non-profit entities

(1)     An entity is a “governmental entity” if—

(a)     it is wholly owned by a national, regional or local government,

(b)     it has the principal purpose of—

(i)     carrying on a public function of that government, or

(ii)     managing or investing the assets of that government through investment activities (such as the making and holding of investments or asset management),

(c)     it is accountable to that government on its overall performance and provides annual information reporting to that government,

(d)     it does not carry on a trade or business, other than an investment business described in paragraph (b)(ii),

(e)     its assets vest in that government

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