‘Excluded dividend’ means a dividend or another distribution received or accrued in respect of an ownership interest, except a dividend or another distribution received or accrued in respect of:

(i)    an ownership interest in an entity of less than 10% (a “portfolio shareholding”) in respect of which a constituent entity is entitled to all or substantially all of the rights to profits, capital or reserves, irrespective of whether the constituent entity owns the legal ownership of such portfolio, for less than one year at the date of the distribution; and

(ii)   an ownership interest in an investment entity that is subject to an election pursuant to Article 41 of EU Directive;

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