Article 27 - Election to Consolidate Transactions of CEs Located in the State

The UPE may elect to apply the consolidated accounting treatment to eliminate income, expenses, gains, and losses arising from transactions between CEs located in the State and included within a tax consolidation Group for the purpose of determining the income or loss of the CEs.

If the UPE is not located in the State, the DCE may make the election mentioned in the first paragraph of this Article on behalf of the UPE.

When this election mentioned in the first paragraph of this Article is made or revoked, adjustments must be made to avoid duplications or omissions of any elements of GloBE Income or Loss as a result of applying or revoking this election.

This election is limited to transactions between CEs located in the State and does not include Investment Entities, MOCEs, JVs, or JV Subsidiaries.

This election mentioned in the first paragraph of this Article is valid for five Tax Periods.

This Article is applied in accordance with the executive rules and instructions issued by the Tax Administration.