Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p138
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 346548–348805

by the disposing Entity because gain from the transaction was included in the taxable income of the disposing Entity.
 (4) In working out amounts under paragraph (3)(b):
 (a) adjust the carrying value of the asset and the value of deferred tax assets that arose in relation to the asset before the transaction for the items in subparagraphs (2)(b)(i) and (ii) (to the extent they are incurred, or would have been recognised, in or after the Transition Year); and
 (b) if, under subsection 3‑200(4), the disposing Entity is included in a tax consolidation group for the purposes of subsection 3‑200(1)—treat other Constituent Entities of the MNE Group that are included in the tax consolidation group as being part of the disposing Entity.
 (5) Subsections (6) and (7) apply if:
 (a) after the transaction, the acquiring Entity records the asset at fair value in its financial accounts; and
 (b) the amount computed under paragraph (3)(b) is greater than the amount computed under paragraph (3)(a).
 (6) If a Filing Constituent Entity for the MNE Group makes a choice under subsection (7), subsection (2) does not apply in relation to the asset.
 (7) For the purposes of subsection (6), a Filing Constituent Entity for the MNE Group may choose for subsection (2) to not apply in relation to the asset.

9‑20  Meaning of Transition Year
  Transition Year, for a jurisdiction, means the first Fiscal Year that the MNE Group comes within the scope of the GloBE Rules in respect of that jurisdiction.

Part 9‑2—Transitional relief for the Substance‑based Income Exclusion

9‑25  Application of this Part
  This Part applies in relation to a Fiscal Year if it begins during the period that:
 (a) starts on 1 January 2023; and
 (b) ends on 31 December 2032.

9‑30  Transitional relief for Payroll Carve‑out Amount
  For the purposes of working out the Payroll Carve‑out Amount for a Constituent Entity of an MNE Group located in a jurisdiction, for a Fiscal Year, under section 5‑55, treat the reference to 5% in paragraph 5‑55(1)(c) as a reference to the percentage specified in the following table:

Payroll carve‑out amount transitional percentages
Item                                               If the Fiscal Year begins in:  the percentage specified is: