Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p61
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 153817–156550

valuation adjustment or accounting recognition adjustment with respect to a deferred tax asset;
 (d) the amount of the relevant deferred tax expense that arises from a re‑measurement with respect to a change in the applicable domestic tax rate;
 (e) the amount of the relevant deferred tax expense that is in respect of the generation and use of tax credits.
 (3) Adjust that Total Deferred Tax Adjustment Amount as follows:
 (a) increase it by the amount of any Unclaimed Accrual paid during the Fiscal Year;
 (b) increase it by the amount of any Recaptured Deferred Tax Liability computed in a preceding Fiscal Year that has been paid during the Fiscal Year;
 (c) if a deferred tax asset has not been recognised in the deferred tax expense mentioned in subsection (1) only because the recognition criteria are not met—reduce it by the amount that would be a reduction to the deferred tax expense if the deferred tax asset were so recognised.
 (4) Subsection (5) applies if:
 (a) a deferred tax asset has been recorded at a rate lower than the Minimum Rate; and
 (b) the deferred tax asset is attributable to a GloBE Loss for a Fiscal Year.
 (5) If this subsection applies:
 (a) recast the deferred tax asset at the Minimum Rate in the Fiscal Year mentioned in paragraph (4)(b) if this reflects the content of the GloBE Information Return for the MNE Group for the Fiscal Year; and
 (b) if the deferred tax asset is recast under paragraph (a)—reduce the Total Deferred Tax Adjustment Amount by the amount by which the deferred tax asset is increased because of that recasting.

4‑90  Total Deferred Tax Adjustment Amount—effect of Substitute Loss Carry‑forward DTA
 (1) This section applies if a Constituent Entity of an MNE Group has a Substitute Loss Carry‑forward DTA.
 (2) Subsection (3) applies if the Substitute Loss Carry‑forward DTA is a Substitute Loss Carry‑forward DTA under subsection 4‑95(2).
 (3) For the purposes of computing the Total Deferred Tax Adjustment Amount of the Constituent Entity for a Fiscal Year, treat the Substitute Loss Carry‑forward DTA as a deferred tax asset in computing the relevant deferred tax expense mentioned in subsection 4‑85(1) in relation to the Fiscal Year.
 (4) In computing the relevant deferred tax expense mentioned in subsection (3), take account of the Substitute Loss Carry‑forward DTA only to the extent the foreign tax credit that gave rise to the Substitute Loss Carry‑forward DTA is used to offset tax liability on income included in the Constituent Entity's GloBE Income or Loss.
 (5) Paragraph 4‑85(2)(e) does not apply in relation to the Substitute Loss Carry‑forward DTA.

4‑95  Meaning of Substitute Loss Carry‑forward DTA
 (1) A Constituent Entity of an MNE Group has