3‑170 Meaning of Aggregate Asset Gain, N

3‑170 Meaning of Aggregate Asset Gain, Net Asset Gain, etc

(1) If the result of the disposition of Local Tangible Assets by all Constituent Entities of an MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is a net gain in a Fiscal Year, then the MNE Group has an Aggregate Asset Gain for the jurisdiction for the Fiscal Year of the amount of that net gain. (2) If the result of the disposition of Local Tangible Assets by a Constituent Entity of the MNE Group located in a jurisdiction, excluding any gain or loss on a transfer of assets between Group Members, is: (a) a net gain in a Fiscal Year—then the Constituent Entity has a Net Asset Gain for the Fiscal Year of that amount; and (b) a net loss in a Fiscal Year—then the Constituent Entity has a Net Asset Loss for the Fiscal Year of that amount, expressed as a positive amount. (3) Local Tangible Asset, in relation to a Constituent Entity located in a jurisdiction, means immovable property located in the jurisdiction.