<< Go back to overview Next article>> Article 3.4 Allocation of Income or Loss between a Main Entity and a Permanent Establishment A PE is a tax rather than an accounting concept. This means that financial accounting information may not always be separately maintained in respect of the PE. [...]
<< Go back to overview Next article>> Article 3.3 International Shipping Exclusion Article 3.3 provides an exclusion for income derived from international shipping. The international shipping industry has long been subject to industry-specific tax rules. The capital intensive nature, the level of profitability and long economic life cycle of [...]
Article 3.2 - Adjustments to determine GloBE Income or Loss Once the Financial Accounting Net Income or Loss of a Constituent Entity is determined, it is adjusted for certain book to tax differences (that is, differences between financial accounting results and taxable income results) that are common in Inclusive Framework jurisdictions. Differences between [...]
Article 3.1 Financial Accounts The GloBE Rules sets out the computation of GloBE Income or Loss for each Constituent Entity. The starting point for this computation is the Financial Accounting Net Income or Loss of the Constituent Entity calculated in accordance with the rules of Article 3.1. 3.1.1. The GloBE Income or [...]
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