Article 4 identifies specific 'Excluded Entities' that are generally exempt from the Domestic Minimum Top-Up Tax provisions, though their revenue still counts toward the EUR 750 million threshold under Article 3. Excluded categories include government bodies, international organisations, non-profit organisations, pension funds, and certain investment or real estate vehicles acting as Ultimate Parent Entities. Entities owned at least 95% or 85% by these groups may also qualify for exclusion under certain conditions. However, pursuant to Paragraph B, a Filing Constituent Entity may make a five-year election to waive this exclusion for specific entities, ensuring flexibility in MNE group tax structuring.