Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p53
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 133886–136513

in which the Constituent Entity is located; and
 (ii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4‑125(2); and
 (iii) if there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity of the MNE Group—the Constituent Entity is not the Ultimate Parent Entity;
  the Constituent Entity's share of that amount, computed based on the Constituent Entity's share of the MNE Group's Net GloBE Income for the Fiscal Year;
 (c) if:
 (i) the Constituent Entity is the Ultimate Parent Entity of the MNE Group; and
 (ii) there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity; and
 (iii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4‑135(2);
  that amount;
 (d) the amount (if any) of Covered Taxes of the Constituent Entity for the Fiscal Year that is paid in the Fiscal Year, to the extent that the amount:
 (i) relates to an uncertain tax position; and
 (ii) was treated as a Reduction to Covered Taxes of the Constituent Entity for a previous Fiscal Year under paragraph 4‑20(1)(e);
 (e) the amount (if any) of credit or refund, in respect of a Qualified Refundable Tax Credit or Marketable Transferable Tax Credit, that is recorded as a reduction, in respect of Covered Taxes, to its Accrued Current Covered Tax Expense for the Fiscal Year.

4‑20  Meaning of Reductions to Covered Taxes
 (1) The Reductions to Covered Taxes of a Constituent Entity for a Fiscal Year is the sum of the following:
 (a) if income is excluded from the computation of the Constituent Entity's GloBE Income or Loss under Chapter 3—the sum of:
 (i) the Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year that relates to the income; and
 (ii) the amount (if any) of Additions to Covered Taxes for the Fiscal Year of the Constituent Entity that relates to the income;
Note: An amount of Covered Taxes in respect of a Net Asset Gain or Net Asset Loss is excluded from the computation of Adjusted Covered Taxes by subsection 3‑160(2).
 (b) the amount (if any) of credit or refund, in respect of a tax credit (other than a Qualified Refundable Tax Credit or a Marketable Transferable Tax Credit), that:
 (i) is credited or refunded to the Constituent Entity in respect of Covered Taxes in the Fiscal Year; and
 (ii) is not recorded as a reduction to the Constituent Entity's Accrued Current Covered Tax Expense for the Fiscal Year;
 (c) if the Constituent Entity transferred a Non‑Marketable Transferable Tax Credit during the Fiscal Year:
 (i) where the Constituent Entity is the person to whom the tax credit was