Eligible Tangible Assets means the following:
Property, plant, and equipment located in the State.
Natural resources located in the State.
The lessee’s right of use to tangible assets located in the State.
Licenses or similar arrangements issued by the government to use immovable property or exploit natural resources in the state, provided they require a significant investment in tangible assets.
The following are not considered part of these assets:
The carrying value of properties, including land or buildings, held for sale, lease, or investment purposes.
The carrying value of tangible assets used to generate International Shipping Income or Qualified Ancillary International Shipping Income. The carrying value of tangible assets attributable to the CE’s income exceeding the maximum Qualified Ancillary International Shipping Income is included in the calculation of Eligible Tangible Assets.
The carrying value of Eligible Tangible Assets is the average carrying value of the tangible assets at the beginning and end of the Tax Period, as reported for the purpose of preparing the CFS of the UPE, after deducting accumulated net depreciation, amortization, or depletion, and adding any amount related to capitalized payroll costs.
The capitalization of payroll costs means the conversion of payroll costs into fixed assets included in the statement of financial position instead of being expensed in the income statement.
When applying the provisions of this Article, the following shall be considered:
The carrying value of Eligible Tangible Assets must be the value recorded in the accounts of the CE that are used in preparing the CFS of the MNE Group.
Tangible assets transferred between members of the MNE Group are not considered.
The carrying value of tangible assets must include adjustments arising from impairment losses.
When accounting standards require the reversal of an impairment loss stated in clause (3) of the previous paragraph, the resulting amount shall be included in the carrying value of the Eligible Tangible Asset at the end of the reported Tax Period, provided that it does not exceed the carrying value of the Eligible Tangible Asset that would have been calculated after depreciation or amortization if the impairment loss had not been recognized.