Examples organised by model-rule article
The document groups illustrations under the relevant GloBE article numbers. Topics span top-up tax allocation, income adjustments, covered taxes and deferred tax, substance-based exclusions, reorganisations, special tax regimes, transition and definitions. This makes it useful for locating a comparable fact pattern after identifying the rule at issue.
Illustrations are not the governing rule
The introduction states that these examples are illustrative and do not themselves form part of the Commentary. Compare the full assumptions, ownership structure, dates and amounts rather than copying an outcome from a superficially similar case. Use the applicable model rule, current Commentary and domestic implementation together. The revised version should not be cited as an unchanged 2022 publication.
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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