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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-5 - INVESTMENT ENTITY TAX TRANSPARENCY ELECTION  

SECTION 7-135   EFFECT OF REVOCATION OF ELECTION - INVESTMENT ENTITY TREATED AS TAX TRANSPARENT ENTITY  

7-135(1)    
Subsection (2) applies if:

(a)    an election under subsection 7-125(1) is revoked; and

(b)    a gain or loss arises from the disposition of an asset or liability held by the Investment Entity; and

(c)    the gain or loss arises in a Fiscal Year to which the election does not apply because of the revocation.

7-135(2)    
For the purposes of this instrument, compute the gain or loss based on the fair value of the asset or liability on the first day of the first Fiscal Year to which the election does not apply because of the revocation.