Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p45
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 113199–116023

which the election applies:
 (a) in computing that amount for a Fiscal Year to which the election applies, adjust the consolidated local entity's Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude income, expenses, gains and losses arising from transactions between consolidated local entities located in the same jurisdiction, to the extent that this reflects the consolidated accounting treatment of the Ultimate Parent Entity;
 (b) in computing that amount for the first Fiscal Year to which the election applies, adjust the consolidated local entity's Financial Accounting Net Income or Loss for the Fiscal Year so as to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising as a result of making the election;
 (c) where the election is revoked in a Fiscal Year—in computing that amount for the Fiscal Year, adjust the consolidated local entity's Financial Accounting Net Income or Loss for the Fiscal Year so as to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising as a result of the revocation.

Interpretation—tax consolidation group
 (4) For the purposes of subsection (1), Constituent Entities of an MNE Group located in a jurisdiction are included in a tax consolidation group if, under the law of that jurisdiction, the income, expenses, gains or losses of those Constituent Entities may be shared for tax purposes because of a connection between the Constituent Entities based on ownership or common control.

3‑205  Adjustment—insurance company amounts charged to policyholders for taxes paid in respect of returns to policy holders
 (1) Subsection (2) applies if a Constituent Entity of an MNE Group is an insurance company.
 (2) In computing the Constituent Entity's GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity's Financial Accounting Net Income or Loss for the Fiscal Year so as to:
 (a) exclude any amount that is charged to policyholders for Taxes paid by the Constituent Entity in respect of returns to the policyholders; and
 (b) include returns to policyholders that are not reflected in the Constituent Entity's Financial Accounting Net Income or Loss for the Fiscal Year, to the extent that a corresponding increase or decrease in liability to policyholders is reflected in its Financial Accounting Net Income or Loss for that Fiscal Year.

3‑210  Adjustment—distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital
 (1) In computing a Constituent Entity's GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity's Financial Accounting Net Income or Loss for the Fiscal Year so as to:
 (a) treat an amount recognised as a decrease to the equity of the Constituent Entity attributable