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

CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES  

PART 6-3 - TRANSFER OF ASSETS AND LIABILITIES  

SECTION 6-55   ACQUISITIONS AND DISPOSALS OF ASSETS AND LIABILITIES  

55(1)    
If a Constituent Entity of an MNE Group (the disposing Constituent Entity ) disposes of an asset or liability, in computing the GloBE Income or Loss of the disposing Constituent Entity for the Fiscal Year in which the disposal occurs, include the gain or loss on the disposal.

55(2)    
If a Constituent Entity of an MNE Group (the acquiring Constituent Entity ) acquires an asset or liability, in determining the GloBE Income or Loss of the acquiring Constituent Entity for a Fiscal Year ending after the acquisition:

(a)    if subsections 6-50(2) and (3) apply in relation to the acquisition - use the fair value of the asset or liability; or

(b)    otherwise - use the acquiring Constituent Entity ' s carrying value of the asset or liability determined under the accounting standard used in preparing Consolidated Financial Statements of the Ultimate Parent Entity of the MNE Group.