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

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 2 - Transitional CbCR Safe Harbour  

Subdivision F - Special rules for particular circumstances  

SECTION 8-100   TRANSITIONAL CbCR SAFE HARBOUR - SPECIAL RULE FOR NET UNREALISED FAIR VALUE LOSS  

8-100(1)    
For the purposes of section 8-10 , in working out the MNE Group ' s Profit (Loss) before Income Tax for the jurisdiction for the Fiscal Year, disregard the MNE Group ' s Net Unrealised Fair Value Loss for the jurisdiction for the Fiscal Year if that Net Unrealised Fair Value Loss exceeds 50 million Euros.

8-100(2)    
An MNE Group ' s Net Unrealised Fair Value Loss for a jurisdiction for a Fiscal Year means the sum of all losses, as reduced by any gains, which arise from changes in fair value of Ownership Interests (except for Portfolio Shareholdings) held by any Constituent Entity of the MNE Group.