6. Company that meets the ownership and base erosion test.

This test generally requires that more than 50% of the vote and value of the company's shares be owned, directly or indirectly, by Qualifying Persons, as long as all companies in the chain of ownership are resident in the same country of residence, and less than 50% of the company's gross income is accrued or paid, directly or indirectly, to persons other than Qualifying Persons.