We provide below an illustration of the options available to Taxable Persons for the relevant asset types in the event they qualify for an adjustment. With regards to Qualifying Financial Assets and Qualifying Financial Liabilities, a Taxable Person may adjust its Taxable Income for the purposes of calculating the gains and losses when the above conditions 1 and 2 apply. The assets are disposed of or deemed to be disposed of after the CT Law becomes effective for a Taxable Person for a value exceeding the net book value (i.e. The assets are accounted for on a historical cost basis and prior to the Taxable Person’s first fiscal year)

The assets are owned before the first Tax Period (i.e. Gains and losses upon disposal of Financial assets and liabilities (to be deemed as “Qualifying Financial Asset” and “Qualifying Financial Liability” in the event the below conditions are met).Ī Taxable Person may elect to adjust their Taxable Income to the extent all of the following conditions are met in the context of Immovable Property and Intangible Assets: Gains upon disposal of Intangible assets (to be deemed as “Qualifying Intangible Asset” in the event the below conditions are met) and

Gains upon disposal of Immovable property (to be deemed as “Qualifying Immovable Property” in the event the below conditions are met)

The Decision provides that a Taxable Person holding one of the below assets may elect* to adjust its Taxable Income for gains or losses recognised upon disposal:

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