# Finance (No. 2) Act 2023, Section 167: Underlying profits of hybrids

Extent: E+W+S+N.I.

(1) This section applies where a member of a multinational group (“M”)—
(a) is not regarded as tax transparent in the territory in which it is located, and
(b) is regarded as tax transparent in a territory in which a member of the group with an ownership interest in it (“G”) is located.
(2) Where—
(a) the adjusted profits of G reflect profits of M, and
(b) the basis for the profits of M being so reflected is that M (along with any other entities through which G holds that interest) is regarded as tax transparent in the territory in which G is located,
such profits as are reflected on that basis are to be allocated to M (and included in the adjusted profits of M to the extent not already included) and excluded from the adjusted profits of G.

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Source: https://www.legislation.gov.uk/ukpga/2023/30/section/167 (the official version)
Page: https://openlegislation.uk/finance-no-2-act-2023/section-167
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.