187 Election for losses to be treated as special loss deferred tax assets

187  Election for losses to be treated as special loss deferred tax assets

(1)     The filing member of a multinational group may elect that this section applies to all of the standard members of the group in a particular territory (“the relevant territory”).

(2)     An election under subsection (1)—

(a)     must be made having effect for the first accounting period in which the Pillar Two rules apply to any standard member in the relevant territory,

(b)     may not otherwise be made (and accordingly if the election is revoked it cannot be made again), and

(c)     may not be

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