This decision clarifies the conditions for subsidiaries of a Government Entity to form a Tax Group for Corporate Tax purposes under Article 40 of the Corporate Tax Law. Subsidiaries where a government entity holds at least a 95% ownership interest may form a group if they meet standard conditions. However, the exempt Government Entity parent and any other exempt subsidiary are explicitly prohibited from being members of the Tax Group. The Government Entity is required to appoint one of the eligible subsidiaries to act as the representative of the Tax Group.