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