8‑30 Meaning of Profit (Loss) before Inc8‑30 Meaning of Profit (Loss) before Income Tax

8‑30 Meaning of Profit (Loss) before Income Tax

(1) An MNE Group’s Profit (Loss) before Income Tax, for a jurisdiction for a Fiscal Year, means the MNE Group’s profit or loss before income tax for the jurisdiction for the Fiscal Year, as reported in its Qualified CbC Report in relation to the jurisdiction for the Fiscal Year. (2) Subsection (3) applies if an intragroup payment that is made between Group Entities of the MNE Group: (a) is treated as income in the Qualified Financial Statements of the recipient Group Entity; and (b) is treated as expense in the Qualified Financial Statements of the paying Group Entity. (3) For the purposes of subsection (1), include the amount of the intragroup payment in the MNE Group’s profit or loss before income tax mentioned in that subsection. (4) For the purposes of subsection (1), if: (a) a Constituent Entity of the MNE Group is a Permanent Establishment; and (b) a loss arising in respect of the Permanent Establishment is allocated to the Permanent Establishment (and not to the Main Entity in respect of the Permanent Establishment); increase the MNE Group’s profit or loss before income tax for the jurisdiction in which the Main Entity is located by the amount of the loss.