{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/section-176F",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/section-176F.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "section/176F",
  "kind": "section",
  "number": "176F",
  "heading": "Flow-through tax benefits: subtraction method",
  "text": "Where this section applies, to determine the extent to which flow-through tax benefits provided to an investor in an accounting period under a tax equity partnership arrangement are qualifying, take the following steps—\nStep 1\nDetermine the amount of capital investment provided by the investor to the arrangement at its commencement.\nStep 2\nSubtract the following from that amount—\n(a)the amounts, if any, of tax credits made available to be used by the investor under the arrangement since the commencement of the arrangement, other than tax credits—\n(i)that were made available in the accounting period, and\n(ii)that are not qualifying refundable tax credits or marketable transferable tax credits;\n(b)the value of the amounts, if any, of tax deductible losses made available to be used by the investor under the arrangement since its commencement, other than losses made available in the accounting period;\n(c)the amounts, if any, of distributions made to the investor since the arrangement’s commencement;\n(d)the amounts, if any, received by the investor for the sale of any part of its investment in the arrangement.\nStep 3\nIf the result of Step 2 is nil or less, no flow-through tax benefits provided under the arrangement in the accounting period are qualifying.\nIf the result of that step is more than nil, proceed to Step 4.\nStep 4\nSubtract the flow-through tax benefits provided to the investor in the accounting period under the arrangement from the result of Step 2.\nStep 5\nIf the result of Step 4 is nil or greater, all of the flow-through tax benefits provided under the arrangement in the accounting period are qualifying.\nOtherwise, the amount of those benefits that is qualifying is the amount of those benefits that when subtracted from the result of Step 2 would give a result of nil.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Ss. 176D-176F and cross-heading 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. 16(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 176F substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 22(2), 72(3)(a)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 176F substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 22(3), 72(3)(a)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/section/176F",
    "retrieved_at": "2026-10-29T08:52:11.242356+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}