Document ID: chunk:federal_register_of_legislation:F2024L01740:reg:10:p4
Version: federal_register_of_legislation:F2024L01740
Segment Type: reg
Provision Reference: reg 10 (pt 4/10)
Character Range: 359022–361921

Loss of a Constituent Entity of an MNE Group for a Fiscal Year is a negative amount, the Constituent Entity's GloBE Loss for the Fiscal Year is the absolute value of that amount.
GloBE Loss Deferred Tax Asset:
 (a) of an MNE Group—means a GloBE Loss Deferred Tax Asset established under subsection 4‑125(1); and
 (b) of an Ultimate Parent Entity—means a GloBE Loss Deferred Tax Asset established under subsection 4‑135(1).
GloBE Loss Election: see subsection 4‑120(1).
GloBE Reorganisation: see subsection 6‑65(1).
High‑Tax Counterparty: see section 3‑190.
Hybrid Arbitrage Arrangement: see section 8‑115.
Hybrid Entity: see section 10‑55.
IIR means any law of a jurisdiction that may reasonably be considered to have been enacted with the intention of implementing, in whole or in part, Articles 2.1 to 2.3 of the GloBE Rules.
IIR Top‑up Tax Amount: see section 2‑5.
Included Revaluation Method Gain or Loss: see subsection 3‑50(1).
Inclusion Ratio: see subsection 2‑15(1).
Income Tax Accrued (Current Year): see subsection 8‑190(2).
Insurance Investment Entity means an Entity that:
 (a) is established in relation to liabilities under an insurance or annuity contract; and
 (b) is wholly‑owned by one or more Entities (the owners) that:
 (i) are subject to regulation as an insurance company in the jurisdiction in which they are located; and
 (ii) if there is more than one owner—are all part of the same MNE Group; and
 (c) but for paragraphs (a) and (b), would be an Investment Fund or a Real Estate Investment Vehicle.
Intermediate Parent Entity means a Constituent Entity of an MNE Group (other than an Ultimate Parent Entity, Partially‑Owned Parent Entity, Permanent Establishment, Investment Entity or Insurance Investment Entity) that holds an Ownership Interest in another Constituent Entity of the MNE Group.
International Shipping Activity: see subsection 3‑225(2).
International Shipping Income: see subsection 3‑225(1).
International Shipping Income Costs: see subsection 3‑225(3).
International Shipping Income Revenue: see subsection 3‑225(2).
Intragroup Financing Arrangement: see section 3‑185.
Investment Entity means:
 (a) an Investment Fund or a Real Estate Investment Vehicle; or
 (b) an Entity that is at least 95% owned directly by an Entity described in paragraph (a) or through a chain of such Entities and that operates exclusively or almost exclusively to hold assets or invest funds for the benefit of such Investment Entities; or
 (c) an Entity, where:
 (i) at least 85% of the value of the Entity is owned by an Entity referred to in paragraph (a); and
 (ii) substantially all of the Entity's income is Excluded Dividends or Excluded Equity Gain or Loss that is excluded from the computation of GloBE Income or Loss under section 3‑20 or 3‑30.
Jurisdictional Top‑up Tax: see section 5‑30.
Local Tangible Asset: see section 3‑170.
Look‑back Period: see section 3‑175.