Article 2 establishes the charging mechanism for Top-up Tax in the UAE. It identifies the liable payers as Constituent Entities, Joint Ventures, and JV Subsidiaries located in the UAE, as well as certain stateless Reverse Hybrid Entities. The provision allows for the appointment of a Domestic Designated Filing Entity to consolidate payment obligations for members of a domestic group. Notably, Investment Entities located in the UAE are explicitly excluded from the Top-up Tax charge under this article, ensuring clarity on the specific entities responsible for settlement.