‘Asymmetric foreign currency gain or loss’ means a foreign currency gain or

loss that is:

(i)    included in the computation of the taxable income or loss of a constituent entity and that are attributable to fluctuations in the exchange rate between the accounting functional currency and the tax functional currency of the constituent entity;

(ii)   included in the computation of the financial accounting net income or loss of a constituent entity and that are attributable to fluctuations in the exchange rate between the accounting functional currency and the tax functional currency of the constituent entity;

(iii)  included in the computation of the financial accounting net income or loss of a constituent entity and that are attributable to fluctuations in the exchange rate between a foreign currency and the accounting functional currency of the constituent entity; and

(iv)  attributable to fluctuations in the exchange rate between a foreign currency and the tax functional currency of the constituent entity.

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