Section 4‑90 Total Deferred Tax Adjustment Amoun - Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 - 4‑90 Total Deferred Tax Adjustment Amount—effect of Substitute Loss Carry‑forward DTA

4‑90 Total Deferred Tax Adjustment Amoun4‑90 Total Deferred Tax Adjustment Amount—effect of Substitute Loss Carry‑forward DTA

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4‑90 Total Deferred Tax Adjustment Amount—effect of Substitute Loss Carry‑forward DTA

(1) This section applies if a Constituent Entity of an MNE Group has a Substitute Loss Carry‑forward DTA. (2) Subsection (3) applies if the Substitute Loss Carry‑forward DTA is a Substitute Loss Carry‑forward DTA under subsection 4‑95(2). (3) For the purposes of computing the Total Deferred Tax Adjustment Amount of the Constituent Entity for a Fiscal Year, treat the Substitute Loss Carry‑forward DTA as a deferred tax asset in computing the relevant deferred tax expense mentioned in subsection 4‑85(1) in relation to the Fiscal Year. (4) In computing the relevant deferred tax expense mentioned in subsection (3), take account of the Substitute Loss Carry‑forward DTA only to the extent the foreign tax credit that gave rise to the Substitute Loss Carry‑forward DTA is used to offset tax liability on income included in the Constituent Entity’s GloBE Income or Loss. (5) Paragraph 4‑85(2)(e) does not apply in relation to the Substitute Loss Carry‑forward DTA.