Why the transition rule is restricted
Article 9.1 allows qualifying historic deferred-tax attributes to avoid distortions on entering GloBE. This package addresses arrangements after 30 November 2021 that could create credits or tax-basis step-ups sheltering future low-taxed income. It also addresses similar retroactive elections and new corporate-tax regime events. The mere existence of an accounting DTA does not establish eligibility.
Review the event and transition conditions
The document provides amendments and a worked example. Check the origin of the benefit, government involvement, event date and detailed exclusions or limited transition treatment before including a reversal in covered taxes. Apply the text alongside the current Commentary and domestic rules, rather than assuming all pre-GloBE loss or credit balances receive identical treatment.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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