Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p89
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 222764–225559

instrument in relation to the acquiring MNE Group, treat the target as a Constituent Entity of that MNE Group for the transfer year; and
 (b) the rules set out in sections 6‑25 to 6‑45 apply.
 (3) To avoid doubt, if both subparagraphs 6‑15(1)(b)(i) and (ii) apply in the transfer year, the target may be treated as a Constituent Entity of both MNE Groups under subsections (1) and (2).

6‑25  Target's Financial Accounting Net Income or Loss and Adjusted Covered Taxes
  For the purposes of this instrument, take into account the Financial Accounting Net Income or Loss and Adjusted Covered Taxes of the target for the transfer year only to the extent that they are taken into account in:
 (a) in applying this instrument in relation to the disposing MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group for the transfer year; or
 (b) in applying this instrument in relation to the acquiring MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group for the transfer year.

6‑30  Historical carrying value of target's assets and liabilities
  For the purposes of applying this instrument in relation to the acquiring MNE Group, in computing the GloBE Income or Loss and Adjusted Covered Taxes of the target in the transfer year and each later Fiscal Year, use the target's historical carrying value of its assets and liabilities.

6‑35  Target's Eligible Payroll Costs and Tangible Asset Carve‑out Amount
 (1) For the purposes of this instrument, in computing the target's Eligible Payroll Costs for the transfer year, take into account only those costs reflected in:
 (a) in applying this instrument in relation to the disposing MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the disposing MNE Group for the transfer year; or
 (b) in applying this instrument in relation to the acquiring MNE Group—the Consolidated Financial Statements of the Ultimate Parent Entity of the acquiring MNE Group for the transfer year.
 (2) For the purposes of this instrument, in computing the Tangible Asset Carve‑out Amount for the target for the transfer year, adjust the carrying value of the target's Eligible Tangible Assets for the transfer year proportionally to correspond with the period in the transfer year in which that the target was a Group Entity of:
 (a) in applying this instrument in relation to the disposing MNE Group—the disposing MNE Group; or
 (b) in applying this instrument in relation to the acquiring MNE Group—the acquiring MNE Group.

6‑40  Deferred tax assets and deferred tax liabilities
 (1) Subsection (2) applies if:
 (a) the target becomes a Constituent Entity of the acquiring MNE Group; and
 (b) a deferred tax asset or deferred tax liability