Paragraph 13 Qualifying current tax expense

Section 174 (amount of covered tax balance) is amended as follows.

In subsection (5), in the definition of “qualifying current tax expense”, for “underlying profits” substitute “partially adjusted profits”.

At the end insert—

“(6)

For the purposes of the definition of “qualifying current tax expense” in subsection (5), the member’s “partially adjusted profits” are its underlying profits with the adjustments contained in the following sections applied—

• section 137A (use of substituted values);

• section 139 (profits adjusted to be profits before consolidation adjustments to eliminate intragroup transactions);

• section 140 (profits adjusted to be profits before certain purchase accounting adjustments).”