Article 15 - Included Revaluation Method Gain or Loss

To determine the GloBE Income or Loss for each CE, the FANIL is adjusted by adding back gains or losses arising from Included Revaluation Method Gain or Loss. These include net gains or losses increased or decreased by any associated Covered Taxes, for the Tax Period in respect of all property, plant and equipment that arises under an accounting method or practice that satisfies all of the following:

1. Periodically adjusts the carrying value of such property to its fair value;

2. Records the changes in value in OCI;

3. Does not subsequently report the gains or losses recorded in OCI through profit and loss.

Any revaluation losses or subsequent incremental increase in depreciation are allowed in the computation of GloBE Income or Loss to the extent they are attributable to revaluation increases or gains included in the computation of GloBE Income or Loss.