6‑60 GloBE Reorganisations6‑60 GloBE Reorganisations

6‑60 GloBE Reorganisations

(1) This section applies if the disposal or acquisition of the asset or liability is part of a GloBE Reorganisation. (2) Despite section 6‑55: (a) in the case of a disposal—in computing the disposing Constituent Entity’s GloBE Income or Loss for the Fiscal Year in which the disposal occurs: (i) if the disposing Constituent Entity recognises a Non‑qualifying Gain or Loss in the GloBE Reorganisation—include the Non‑qualifying Gain or Loss; or (ii) otherwise—exclude the gain or loss on the disposal; and (b) in the case of an acquisition—in computing the GloBE Income or Loss of the acquiring Constituent Entity for a Fiscal Year ending after the acquisition: (i) use the disposing Entity’s carrying value of the asset or liability immediately before the disposal; and (ii) adjust the carrying value in a manner consistent with the tax laws of the jurisdiction in which the acquiring Constituent Entity is located, to take into account any Non‑qualifying Gain or Loss arising from the disposal.