To determine the GloBE Income or Loss, the FANIL is adjusted for Asymmetric Foreign Currency Gains or Losses of a CE where its Functional Accounting Currency differs from its Functional Tax Currency. These gains or losses include:
Gains or losses included in the computation of a CE’s taxable income or loss and attributable to fluctuations in the exchange rate between its Accounting Functional Currency and its Tax Functional Currency.
Gains or losses included in the computation of a CE’s FANIL and attributable to fluctuations in the exchange rate between its Tax Functional Currency and its Accounting Functional Currency;
Gains or losses included in the computation of a CE’s FANIL and attributable to fluctuations in the exchange rate between a Third Foreign Currency and its Accounting Functional Currency; and
Gains or losses included in the computation of a CE’s FANIL, attributable to fluctuations in the exchange rate between a Third Foreign Currency and its Tax Functional Currency, whether or not such foreign currency gain or loss is included in taxable income.