Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p21
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 52961–55776

included in the separate financial accounts of the Permanent Establishment in accordance with Part 3‑4 (for the purposes of computing the Financial Accounting Net Income or Loss of the Permanent Establishment); and
 (d) treat the tangible assets of the Main Entity in respect of the Permanent Establishment as not including the tangible assets mentioned in paragraph (c).

2‑95  Employees and the Net Book Value of Tangible Assets allocated from Flow‑through Entity
 (1) For the purposes of sections 2‑65 and 2‑70, if a Constituent Entity of an MNE Group is a Flow‑through Entity that is a Stateless Constituent Entity:
 (a) allocate, in accordance with subsection (2), the employees and the Net Book Value of Tangible Assets of the Flow‑through Entity to the Constituent Entities (if any) of the MNE Group that are located in the jurisdiction in which the Flow‑through Entity was created (each of which is a receiving Constituent Entity); and
 (b) to the extent that the employees and the Net Book Value of Tangible Assets of the Flow‑through Entity are not allocated under paragraph (a)—disregard the employees and the Net Book Value of Tangible Assets.
 (2) The number of employees of the Flow‑through Entity, or the Net Book Value of Tangible Assets of the Flow‑through Entity, that are allocated under paragraph (1)(a) to a receiving Constituent Entity is:
 (a) the number of those employees, or that Net Book Value of Tangible Assets;
multiplied by:
 (b) the percentage computed under the formula in subsection 2‑70(3) in respect of the receiving Constituent Entity.
 (3) If the Flow‑through Entity is a Main Entity in respect of a Permanent Establishment, subsection (1) operates subject to section 2‑90.

Chapter 3—Computation of GloBE Income or Loss

Part 3‑1—Financial accounts

3‑5  Meaning of GloBE Income or Loss
  The GloBE Income or Loss of a Constituent Entity of an MNE Group for a Fiscal Year is the Financial Accounting Net Income or Loss for the Constituent Entity for the Fiscal Year, adjusted as provided in this instrument.

3‑10  Meaning of Financial Accounting Net Income or Loss
 (1) The Financial Accounting Net Income or Loss for a Constituent Entity of an MNE Group for a Fiscal Year is the net income or loss determined for the Constituent Entity (before any consolidation adjustments eliminating intra‑group transactions) in preparing Consolidated Financial Statements of the Ultimate Parent Entity of the MNE Group for the Fiscal Year.
 (2) For the purposes of subsection (1), take into account items of income and expense in the Consolidated Financial Statements only to the extent that those items:
 (a) reliably and consistently reflect the affairs of the Constituent Entity; and
 (b) are not reflected in the separate financial accounts of the Constituent Entity.
 (3) To avoid