Paragraph 14 Straddle periodsF1

(1)

This paragraph applies in relation to an accounting period of a member of a multinational group if—

(a)

21 July 2025 falls during the period (but is not the first day of the period),

(b)

the member has a relevant pre-entry deferred tax asset or a relevant pre-entry deferred tax liability, and

(c)

the asset or liability is reversed (to any extent) in the period.

(2)

Despite section 185(7D) and paragraphs 2(3)(c) and 5(1)(c) of this Schedule, an amount in respect of the reversal may be reflected in—

(a)

the member’s deferred tax expense for the purposes of this Part of this Act, or

(b)

the member’s qualifying income tax expense for the purposes of Part 2 of this Schedule.

(3)

The amount that may be reflected in respect of the reversal is the pre-commencement proportion of the amount that could be so reflected if section 185(7D) or paragraph 2(3)(c) or 5(1)(c) of this Schedule (as the case may be) did not apply to the asset or liability.

(4)

In this paragraph “the pre-commencement proportion” means—

(a)

the number of days in the accounting period before 21 July 2025, divided by

(b)

the total number of days in the accounting period.

Annotations

Textual amendments

F1: Sch. 16 Pt. 4 inserted (in relation to accounting periods ending on or after 21.7.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 21(4), 53(2)