|An Entity is a “Related Entity” of another Entity if either Entity controls the other Entity, or the two Entities are under common control. For this purpose control includes direct or indirect ownership of more than 50% of the vote and value in an Entity.|
|An entity that is related to another entity under an applicable Model 1 or 2 IGA. An entity is related to another if either entity controls the other or the two entities are under common control. Control includes direct or indirect ownership of more than 50 percent of the vote or value in an entity.|
Related Entities are generally defined as one entity that controls another entity or two or more entitiesthat are under common control. Control is defined to include direct orindirect ownership of more than 50 percent of the vote and value in an Entity. As provided in the Commentary, most funds will likely not qualify as a Related Entity of another fund, and thus will not be able toapply the rules described above for treating certain New Accounts as Preexisting Accounts or apply the account aggregation rules to Financial Accounts maintained by Related Entities. A jurisdiction maymodify the definition of Related Entity so that a fund will qualify as aRelated Entity of another fund by providing that control includes, withrespect to Investment Entities described in subparagraph (A)(6)(b), twoentities under common management, and such management fulfils the due diligence obligations of such Investment Entities. A similarapproach can be achieved under FATCA by applying the Sponsoring Regime. The EU Directive also provides this modification.