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

CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES  

PART 6-2 - CONSTITUENT ENTITIES JOINING AND LEAVING AN MNE GROUP  

Division 1 - Transfers of Ownership Interests  

SECTION 6-25  

6-25   TARGET ' S FINANCIAL ACCOUNTING NET INCOME OR LOSS AND ADJUSTED COVERED TAXES  
For the purposes of this instrument, take into account the Financial Accounting Net Income or Loss and Adjusted Covered Taxes of the target for the transfer year only to the extent that they are taken into account in:

(a)    in applying this instrument in relation to the disposing MNE Group - the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group for the transfer year; or

(b)    in applying this instrument in relation to the acquiring MNE Group - the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group for the transfer year.