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 1 - Article 3.2.1 adjustments  

SECTION 3-31   ADJUSTMENT - EXCLUDED EQUITY GAIN OR LOSS - ELECTION  

3-31(1)    
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to a specified jurisdiction.

3-31(2)    
An election under subsection (1) is a Five-Year Election.

Revocation

3-31(3)    
An election under subsection (1) may be revoked, however, a revocation is not effective in respect of an Ownership Interest if an adjustment mentioned in subsection 3-32(2) is made in relation to a loss mentioned in that subsection in respect of that Ownership Interest.

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