https://www.taxtmi.com/article/detailed?id=11182 Article 9.1.3 requires that where an asset is transferred in the Pre-GloBE period between entities that would be part of the same MNE Group, the acquiring entity must use the disposing entity's carrying value and associated deferred tax assets and liabilities to determine the opening carrying value at the start of the Transition Year. Administrative Guidance treats as transfers any transaction or restructuring that creates or increases carrying value in financial accounts and recognizes corresponding income in the Pre-GloBE period, including intra-group cost recordings, deemed internal transfers, and accounting recognition preceding legal transfer. en-us Thu, 09 Mar 2023 09:35:48 +0530 Thu, 09 Mar 2023 09:35:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11182 Article 9.1.3 requires that where an asset is transferred in the Pre-GloBE period between entities that would be part of the same MNE Group, the acquiring entity must use the disposing entity's carrying value and associated deferred tax assets and liabilities to determine the opening carrying value at the start of the Transition Year. Administrative Guidance treats as transfers any transaction or restructuring that creates or increases carrying value in financial accounts and recognizes corresponding income in the Pre-GloBE period, including intra-group cost recordings, deemed internal transfers, and accounting recognition preceding legal transfer. Articles Income Tax Thu, 09 Mar 2023 09:35:48 +0530 https://www.taxtmi.com/article/detailed?id=11182