(a) an entity (the relevant entity ) that is an * outward investing entity (non - ADI), or an * outward investing entity (ADI), for a period (the relevant period ) that is all or a part of an income year; and
(b) each entity ( controlled entity of the relevant entity ) that is an * Australian controlled foreign entity of which:
(i) the relevant entity is an * Australian controller; or
(ii) an * associate entity of the relevant entity is an
Australian controller.