Exclusions from CFCs:

• Income obtained by the taxpayer through a foreign tax transparent entity or foreign legal entity in which the taxpayer has a direct interest, regardless of whether the latter's income is subject to a preferential tax regime.

• Income obtained by the taxpayer through a foreign tax transparent entity or foreign legal entity, regardless of whether it is subject to a preferential tax regime, when the taxpayer's indirect interest in said entity or legal entity is constituted by a structure that exclusively integrates one or more foreign tax transparent entities or foreign legal entities.

The foregoing applies to income obtained by the taxpayer through each of these entities or entities that comprise said structure.