https://www.taxtmi.com/article/detailed?id=11584 Article 6.2 treats a target that joins or leaves an MNE Group during a Fiscal Year as a Constituent Entity of both disposing and acquiring groups for GloBE purposes, with each group taking into account only amounts shown in its Ultimate Parent Entity's consolidated financial statements for the period of ownership. The target computes GloBE Income or Loss and Adjusted Covered Taxes using historical carrying values, excluding purchase-accounting step-ups and acquisition-related intangible adjustments. Eligible Payroll Costs and Eligible Tangible Assets for the Substance-based Income Exclusion are allocated pro rata to the period of ownership, with tangible asset fair-value step-ups permitted for the carveout. en-us Fri, 07 Jul 2023 10:28:36 +0530 Fri, 07 Jul 2023 10:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11584 Article 6.2 treats a target that joins or leaves an MNE Group during a Fiscal Year as a Constituent Entity of both disposing and acquiring groups for GloBE purposes, with each group taking into account only amounts shown in its Ultimate Parent Entity's consolidated financial statements for the period of ownership. The target computes GloBE Income or Loss and Adjusted Covered Taxes using historical carrying values, excluding purchase-accounting step-ups and acquisition-related intangible adjustments. Eligible Payroll Costs and Eligible Tangible Assets for the Substance-based Income Exclusion are allocated pro rata to the period of ownership, with tangible asset fair-value step-ups permitted for the carveout. Articles Other Topics Fri, 07 Jul 2023 10:28:36 +0530 https://www.taxtmi.com/article/detailed?id=11584