Article 11 clarifies the treatment of Joint Ventures (JVs) and their subsidiaries under the Bahrain DMTT framework. A Joint Venture is defined as an entity where the Ultimate Parent Entity holds at least 50% ownership and reports results using the equity method. Pursuant to Paragraph C, JVs and their subsidiaries are treated as a separate MNE Group for tax computation purposes, with the JV acting as the Ultimate Parent Entity. This ensures that the 15% minimum tax applies to JVs independently. Permanent establishments of a JV are treated as separate JV subsidiaries, maintaining consistency with OECD Pillar Two administrative guidance.