Article 10 - Adjustments to Determine the GloBE Income or Loss

The financial accounting net income or loss shall be adjusted to determine the GloBE Income or Loss for each CE in accordance with the following clauses:

1. Net tax expenses;

2. Excluded Dividends or Share Distributions;

3. Excluded Equity Gain or Loss;

4. Gains or losses on foreign exchange related to hedging instruments;

5. Included Revaluation Methods Gain or Loss;

6. Gains or losses from the disposition of excluded assets and liabilities;

7. Asymmetric foreign currency gains or losses;

8. Illegal Payments, Fines and Penalties;

9. Prior Tax Period errors and changes in accounting principles;

10. Accrued pension expenses;

11. Debt releases;

12. Stock-Based Compensation;

13. Arm’s Length Principle requirements;

14. QRTC and Marketable Transferable Tax Credits;

15. Election to use Realization Method in lieu of fair value accounting;

16. Election to spread capital gains over five-Tax Periods;

17. Intragroup financing arrangements;

18. Election to consolidate transactions of Constituent Entities within the State;

19. Exclusion of certain insurance company income;

20. Additional Tier 1 Capital and Restricted Tier 1 Capital;

21. International shipping and maritime income exclusion;

22. Transactions involving Constituent Entities that join or leave the MNE Group;

23. Reduction of GloBE income for a UPE that is a Flow-through Entity;

24. Taxable Distribution Method Election;

25. Transactions between Constituent Entities;

Adjustments shall be made in accordance with Articles 11 to 30, and Articles 51, 52, 55, 58, and 115 of these ERs.

Requirements in Chapter 6 to 8 and Chapter 18 of these ERs must also be considered when adjusting the financial accounting net income or loss of the CE.