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May 15, 2026

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES

Article 59 - Equity Investment Inclusion Election and Qualified Flow-through Tax Benefits

Accounting gains, profits, or losses included in GloBE income or loss must be adjusted in accordance with the provisions of Article 13 of these ERs, except as provided in paragraph (3) of its first chapter.

If the election to include investments in equity is made, all current and deferred tax expenses or benefits arising from the accounting gains, profits, or losses included in GloBE income or loss under the first paragraph of this Article must be included in the adjusted covered taxes account, taking into account the relevant provisions of these ERs.

The owner subject to the Equity Investment Inclusion Election may not apply the two previous paragraphs to the Qualified Flow-Through Tax Benefits of Qualified Ownership Interests, and the following provisions shall apply in this case: