Relevant revenue accounts for one third or less of the total revenue of the entity or permanent establishment, the entity or permanent establishment shall not be treated as a controlled foreign company.
Financial undertaking shall not be treated as controlled foreign company if one third or less of the relevant revenue  comes from transactions with the taxpayer or its associated companies.
This exemptions shall not apply when the entity or permanent establishment are located in countries included in the EU list of non-cooperative jurisdictions for tax purposes.