DISTRIBUTION & SERVICE CENTER
ECONOMIC SUBSTANCE OUTSOURCING

An entity engages in "distribution and service center business" where it conducts the business of either or both of the following: 

1. Purchasing from an entity in the same corporate group: (i) component parts or materials for goods; or (ii) goods ready for sale, and reselling such component parts, materials or goods outside the Jurisdiction;

2. Providing services to an entity in the same corporate group in connection with the business outside the Jurisdiction,

but does not include any activity included in any other relevant activity except holding company business.