Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
If the result of the disposition of Local Tangible Assets by all Constituent Entities of an MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is a net gain in a Fiscal Year, then the MNE Group has an Aggregate Asset Gain for the jurisdiction for the Fiscal Year of the amount of that net gain.
3-170(2)
If the result of the disposition of Local Tangible Assets by a Constituent Entity of the MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is: (a) a net gain in a Fiscal Year - then the Constituent Entity has a Net Asset Gain for the Fiscal Year of that amount; and (b) a net loss in a Fiscal Year - then the Constituent Entity has a Net Asset Loss for the Fiscal Year of that amount, expressed as a positive amount.
3-170(3)
Local Tangible Asset , in relation to a Constituent Entity located in a jurisdiction, means immovable property located in the jurisdiction.
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