Section 148C Value of marketable transferable tax credits: purchaserF1

(1)

The underlying profits of a member of a multinational group that is the purchaser in relation to a marketable transferable tax credit are to be adjusted to secure that the value of marketable transferable tax credits it holds, and has held, as purchaser are reflected as follows.

(2)

On using an amount of the credit in an accounting period, the amount given by subsection (3) is to be recognised as income.

(3)

That amount is the amount given by multiplying—

(a)

the amount used divided by the full value of the credit, by

(b)

the amount given by subtracting the purchase price of the credit from the full value of the credit.

(4)

On transferring the credit, the amount in subsection (5) is to be reflected in the underlying profits for the accounting period in which the transfer occurred—

(a)

if positive, as a gain, or

(b)

if negative, as a loss.

(5)

That amount is the amount given by subtracting—

(a)

the sum of—

(i)

the purchase price of the credit, and

(ii)

any amounts recognised as income in accordance with subsection (2) (whether in that accounting period or a previous accounting period), from

(b)

the sum of—

(i)

the amount of the credit that has been used, and

(ii)

the consideration for the transfer.

(6)

Where the credit has not been transferred, and was not fully used, before its expiry, the amount in subsection (7) is to be reflected as a loss in the accounting period in which the credit expired.

(7)

That amount is the amount given by subtracting—

(a)

the amount of the credit that was used, from

(b)

the sum of the purchase price of the credit and any amounts recognised in accordance with subsection (2).

Annotations

Textual amendments

F1: Ss. 148A-148C inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(3)

Notes on Part 3

Modifications

C1: Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3)