Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p65
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 163789–166314

MNE Group made under subsection (2) of this section.
 (5) If the Filing Constituent Entity revokes a GloBE Loss Election for the MNE Group made under subsection (2), the election does not apply to:
 (a) the Fiscal Year for which the GloBE Information Return for the Applicable MNE Group that records the revocation is filed by the Filing Constituent Entity; and
 (b) each subsequent Fiscal Year.

4‑125  GloBE Loss Deferred Tax Asset of an MNE Group

Establishment and increase
 (1) If a GloBE Loss Election for an MNE Group made under subsection 4‑120(2) applies to a jurisdiction and a Fiscal Year under subsection 4‑120(3):
 (a) Part 4‑4 does not apply to a Constituent Entity of the MNE Group that is located in the jurisdiction in the Fiscal Year; and
 (b) if there is a Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year and a GloBE Loss Deferred Tax Asset of the MNE Group for the jurisdiction has not been established:
 (i) a GloBE Loss Deferred Tax Asset of the MNE Group for the jurisdiction is established; and
 (ii) the amount of that GloBE Loss Deferred Tax Asset is the Net GloBE Loss multiplied by the Minimum Rate; and
 (c) if there is a Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year and a GloBE Loss Deferred Tax Asset of the MNE Group for the jurisdiction has been established:
 (i) the GloBE Loss Deferred Tax Asset is increased; and
 (ii) the amount of that increase is the Net GloBE Loss multiplied by the Minimum Rate.
Note: Modifications may apply to the computation of Net GloBE Loss for the purposes of this subsection if a GloBE Loss Election for the Ultimate Parent Entity of the MNE Group also applies to the Fiscal Year: see subsections 4‑135(3) and (4).

Use
 (2) If there is Net GloBE Income of the MNE Group for the jurisdiction for a Fiscal Year after the Fiscal Year in which the GloBE Loss Deferred Tax Asset is established, use an amount of the GloBE Loss Deferred Tax Asset for the Fiscal Year, for the purposes of paragraph 4‑15(b), equal to the lower of the following:
 (a) the Net GloBE Income multiplied by the Minimum Rate;
 (b) the amount of the GloBE Loss Deferred Tax Asset that has not been previously used under this subsection.
Note: Modifications may apply to the computation of Net GloBE Income for the purposes of this subsection if a GloBE Loss Election for the Ultimate Parent Entity of the MNE Group also applies to the Fiscal Year: see subsections 4‑135(3) and (4).

Reduction to zero
 (3) If a GloBE Loss Election for an