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 3-55   ADJUSTMENT - ASYMMETRIC FOREIGN CURRENCY GAINS OR LOSSES  

3-55(1)    
This section applies if a Constituent Entity ' s accounting functional currency for a Fiscal Year is different from its tax functional currency for the Fiscal Year.

3-55(2)    
In computing the Constituent Entity ' s GloBE Income or Loss for the Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to include a particular amount of taxable income or loss to the extent that:

(a)    the particular amount is:

(i) attributable to fluctuations in the exchange rate between the accounting functional currency and tax functional currency; and

(ii) included in computing the Constituent Entity ' s taxable income or loss; and

(iii) not included in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year; or

(b)    the particular amount is:

(i) attributable to fluctuations in the exchange rate between the tax functional currency and another currency that is not the accounting functional currency; and

(ii) not included in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year (whether or not the particular amount is included in the Constituent Entity ' s taxable income or loss).

3-55(3)    
In computing the Constituent Entity ' s GloBE Income or Loss for the Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude a particular amount of income or loss to the extent that:

(a)    the particular amount is:

(i) attributable to fluctuations in the exchange rate between the accounting functional currency and tax functional currency; and

(ii) included in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year; and

(iii) not included in computing the Constituent Entity ' s taxable income or loss; or

(b)    the particular amount is:

(i) attributable to fluctuations in the exchange rate between the accounting functional currency and another currency that is not the tax functional currency; and

(ii) included in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year; and

(iii) not included in computing the Constituent Entity ' s taxable income or loss.

3-55(4)    
To avoid doubt, disregard the operation of subsections (2) and (3) in determining whether the condition in subparagraph (2)(a)(iii) or (b)(ii) or (3)(a)(ii) or (b)(ii) is met.