HEADQUARTERS BUSINESS
ECONOMIC SUBSTANCE OUTSOURCING

An entity engages in "headquarters business" where it is in the business of providing any of the following services to an entity in the same corporate group:

1. the provision of senior management;

2. the assumption or control of material risk for activities carried out by any of those entities in the same corporate group; or

3. the provision of substantive advice in connection with the assumption or control of risk referred to in paragraph (2),

but does not include banking business, financing and leasing business, fund management business, intellectual property business, holding company business or insurance business.