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Article 6 prescribes the methodology for computing the income or loss of a Constituent Entity for a given fiscal year. Pursuant to Paragraph A, the income or loss is primarily based on the Financial Accounting Net Income or Loss as reported in the entity's financial statements. Importantly, Paragraph B specifies that this figure must be determined before any consolidation adjustments that eliminate intra-group transactions, following Local Financial Accounting Standards. The National Bureau for Revenue will provide further guidance through Executive Regulations to ensure these computations remain consistent with the OECD Pillar Two Model Rules, administrative guidance, and relevant international tax commentaries.
Chapter 2 - Scope and Imposition of the Tax
Article 6 - Computation of Constituent Entity Income or Loss
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