Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
This section applies if the disposal or acquisition of the asset or liability is part of a GloBE Reorganisation.
6-60(2)
Despite section 6-55 : (a) in the case of a disposal - in computing the disposing Constituent Entity ' s GloBE Income or Loss for the Fiscal Year in which the disposal occurs:
(i) if the disposing Constituent Entity recognises a Non-qualifying Gain or Loss in the GloBE Reorganisation - include the Non-qualifying Gain or Loss; or
(b) in the case of an acquisition - in computing the GloBE Income or Loss of the acquiring Constituent Entity for a Fiscal Year ending after the acquisition:
(ii) otherwise - exclude the gain or loss on the disposal; and
(i) use the disposing Entity ' s carrying value of the asset or liability immediately before the disposal; and
(ii) adjust the carrying value in a manner consistent with the tax laws of the jurisdiction in which the acquiring Constituent Entity is located, to take into account any Non-qualifying Gain or Loss arising from the disposal.
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