Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 3 - COMPUTATION OF GloBE INCOME OR LOSS  

PART 3-2 - ADJUSTMENTS TO DETERMINE GloBE INCOME OR LOSS  

Division 2 - Other Article 3.2 adjustments  

SECTION 3-170   MEANING OF AGGREGATE ASSET GAIN, NET ASSET GAIN, ETC  

3-170(1)    
If the result of the disposition of Local Tangible Assets by all Constituent Entities of an MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is a net gain in a Fiscal Year, then the MNE Group has an Aggregate Asset Gain for the jurisdiction for the Fiscal Year of the amount of that net gain.

3-170(2)    
If the result of the disposition of Local Tangible Assets by a Constituent Entity of the MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is:

(a)    a net gain in a Fiscal Year - then the Constituent Entity has a Net Asset Gain for the Fiscal Year of that amount; and

(b)    a net loss in a Fiscal Year - then the Constituent Entity has a Net Asset Loss for the Fiscal Year of that amount, expressed as a positive amount.

3-170(3)    
Local Tangible Asset , in relation to a Constituent Entity located in a jurisdiction, means immovable property located in the jurisdiction.