[ESMA70-145-408 SSR Q&A, Q&A 4.3]

Article 10 of the Regulation specifies that the notification and disclosure requirements apply to any legal person irrespective of where that person is domiciled or established. Therefore, there is no distinction to be drawn between a legal entity or a group in the EU or in a third country as to how they have to calculate their net short position in a given issuer and report it when a notification/disclosure threshold is reached or crossed.