Paragraph 6B Duplicate tax recognition arrangementsF1
Where the aggregate qualifying income tax expense of the standard members of a multinational group in a territory reflects disqualified tax expense, the aggregate qualifying income tax expense is to be adjusted to exclude it.
Disqualified tax expense means any qualifying income tax expense of a member of a multinational group reflected in the financial statements of the member that, as a result of qualifying arrangements, is also reflected in—
the covered tax balance of one or more other members of the group, or
the qualifying income tax expense of one or more other members of the group.
But qualifying income tax expense is not to be regarded as disqualified tax expense—
if the income to which the tax expense relates is reflected in the financial statements of each member of the group falling within sub-paragraph (2)(a) and (b) to at least the same extent to which the tax expense is reflected in the covered tax balance, or qualifying income tax expense, of each of those members;
to the extent that the duplication of the tax expense would not arise if the adjustments that would have been made in determining the member’s covered tax balance (and that are not required to be made for the purpose of determining the member’s qualifying income tax expense) had been made.
Annotations
Textual amendments
- F1
Sch. 16 paras. 6A, 6B and cross-headings inserted (in relation to accounting periods commencing on or after 31.12.2023 (subject to sub-paragraph (2) of the amending paragraph)) by Finance Act 2025 (c. 8), Sch. 4 para. 47(1)(2), 72(2)
Notes on Chapter 1
Textual amendments
- F1
Words in Sch. 16 Pt. 2 Ch. 1 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(2), 10