Paragraph 15 Qualifying current tax expense

Section 182 (total deferred tax adjustment amount) is amended as follows.

In subsection (1), from the words from “underlying profits” to the end substitute “partially adjusted profits, but with that deferred tax expense adjusted as follows”.

After subsection (2) insert—

“(2A)

The deferred tax expense is to be adjusted to include (so far as it would not already) any amount of deferred tax expense in respect of covered taxes within section 176(2)(g) or (h) (amounts reflected in other comprehensive income etc).”

In subsection (8), at the appropriate place insert—

• ““partially adjusted profits”, in relation to a member of a multinational group, means 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).”