Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p2
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 2968–6340

tax/accounting permanent differences in respect of cross‑border transactions
3‑100 Adjustment—Arm's Length Principle and transactions between Constituent Entities located in the same jurisdiction
3‑105 Meaning of Arm's Length Principle
3‑110 Adjustment—Refundable Tax Credits and transferable tax credits
3‑115 Qualified Refundable Tax Credits—amounts
3‑120 Marketable Transferable Tax Credits—amounts
3‑125 Meaning of Qualified Refundable Tax Credit, Non‑Qualified Refundable Tax Credit and Refundable Tax Credit
3‑130 Meaning of Marketable Transferable Tax Credit
3‑135 Meaning of Marketable Price Floor
3‑140 Meaning of Non‑Marketable Transferable Tax Credit and Other Tax Credit
3‑145 Adjustment—loss on transfer of purchased Non‑Marketable Transferable Tax Credits
3‑150 Adjustment—assets and liabilities that are subject to fair value or impairment accounting
3‑155 Adjustment—Aggregate Asset Gain—election
3‑160 Adjustment—Aggregate Asset Gain—effect
3‑165 Adjustment—Aggregate Asset Gain—allocation of amounts
3‑170 Meaning of Aggregate Asset Gain, Net Asset Gain, etc
3‑175 Meaning of Look‑back Period and Loss Year
3‑180 Adjustment—Intragroup Financing Arrangements
3‑185 Meaning of Intragroup Financing Arrangement
3‑190 Meaning of Low‑Tax Entity and High‑Tax Counterparty
3‑195 Meaning of Low‑Tax Jurisdiction
3‑200 Adjustment—election to apply consolidated accounting treatment
3‑205 Adjustment—insurance company amounts charged to policyholders for taxes paid in respect of returns to policy holders
3‑210 Adjustment—distributions paid or payable in respect of Additional Tier One Capital or Restricted Tier One Capital
3‑215 Adjustments as necessary for Chapters 6 and 7
Part 3‑3—International Shipping Income exclusion
3‑220 Adjustment—certain shipping income
3‑225 Meaning of International Shipping Income, etc.
3‑230 Meaning of Qualified Ancillary International Shipping Income, etc.
3‑235 International traffic
Part 3‑4—Allocation of income or loss between a Main Entity and a Permanent Establishment
3‑240 Meaning of Financial Accounting Net Income or Loss—Permanent Establishment
3‑245 Adjustment of Permanent Establishment's Financial Accounting Net Income or Loss
3‑250 Computing GloBE Income or Loss of the Main Entity in respect of a Permanent Establishment
Part 3‑5—Allocation of income or loss from a Flow‑through Entity
3‑255 Constituent Entity that is a Flow‑through Entity—Financial Accounting Net Income or Loss
Chapter 4—Computation of Adjusted Covered Taxes
Part 4‑1—Adjusted Covered Taxes
4‑5 Meaning of Adjusted Covered Taxes
4‑10 Meaning of Accrued Current Covered Tax Expense
4‑15 Meaning of Additions to Covered Taxes
4‑20 Meaning of Reductions to Covered Taxes
4‑25 No double counting of Covered Taxes
4‑30 Additional Current Top‑up Tax where MNE Group has no Net GloBE Income and tax falls short of expected tax
4‑35 Additional Current Top‑up Tax under section 4‑30—Excess Negative Tax Expense Carry‑forward
Part 4‑2—Definition of Covered Taxes
4‑40 Meaning of Covered Taxes
Part 4‑3—Allocation of Covered Taxes from one Constituent Entity to another Constituent Entity
4‑45 Allocation of amounts from Constituent Entity to Permanent Establishment—general rule
4‑50 Allocation of amounts from Tax Transparent Entity to a Constituent Entity‑owner of the Tax Transparent Entity
4‑55 Allocation of amounts from Constituent Entity‑owner