Where an entity or permanent establishment is treated as a controlled foreign company on the basis of the test the taxpayer shall include in the tax base the non-distributed income of the entity or the income of the permanent establishment which is derived from the following categories:
1.	interest or any other income generated by financial assets;
2.	royalties or any other income generated from intellectual property;
3.	dividends and income from the disposal of shares;
4. income from financial leasing;
5. income from insurance, banking and other financial activities;
6. income from invoicing companies that earn sales and services income from goods and services purchased from and sold to associated enterprises, and add no or little economic value