Legal entities are usually not fully autonomous, but are part of a larger economic unit. Often, there exists a certain connection with other legal entities. For instance, this is the case when a legal entity holds all or part of the shares in another legal entity. In principle, a legal entity is taxed separately from its shareholders. In OECD MTC based tax treaties, the starting point is also that each individual legal entity must be considered for the application of the treaty (separate entity approach). In treaty relations, deviation from the principle that entities in a group should be treated as separate entities is exceptional.