Section 273 Determining top-up amounts of entity that is not a member of a group

references to “member of a multinational group” (however framed and including references to multiple members) were to “qualifying entity”;

any reference (however framed) to the consolidated financial statements of the ultimate parent were to the qualifying financial statements of the entity;

F3in section 182(2)(e), after “credits”, in the first place it occurs, there were inserted “other than qualifying refundable tax credits”;

in section 194 (total top-up amount), subsections (2) to (7) were omitted;

in section 203 (additional top-up amounts: covered taxes less than expected), subsections (3) to (7) were omitted;

in section 206 (additional top-up amounts: recalculations), subsections (4) to (8) were omitted.

in section 134 (underlying profits as determined for statements of ultimate parent), subsections (2) to (9);

section 135 (permanent establishments);

section 139 (consolidation adjustments);

section 140 (purchase accounting adjustments);

in section 141 (general exclusion of dividends), F5subsection (3)(c);

section 149 (arm’s length requirement);

section 150 (transactions between group members);

section 154 (exclusion of qualifying intra-group financing arrangement expenses);

sections 159 and 160 (adjustments applicable to permanent establishments);

in section 163 (election to spread capital gains), subsection (3);

section 164 (election to exclude intra-group transactions);

section 167 (underlying profits of member of group seen as transparent);

in section 168 (underlying profits of flow-through entities), subsection (8);

section 169 (non-tax resident entities to be treated as flow-through entities);

section 170 (adjustments for ultimate parent that is flow-through entity);

section 172 (ultimate parent subject to deductible dividend regime);

F6in section 173 (covered taxes), subsection (1)(b);

section 177 (allocation of covered taxes: permanent establishments);

section 178 (reallocation of tax expense);

sections 179 and 180 (controlled foreign company tax regimes);

section 181 (distributions from other group members);

section 183 (qualifying foreign tax credits);

sections 189 to 192 (deemed distribution tax election);

sections 208 to 212 (restructuring of groups);

sections 213 to 215 (elections in relation to investment entities);

in section 216 (election where assets and liabilities adjusted to fair value), subsection (6);

sections 226 to 229 (joint venture groups, minority owned members and multi-parent groups).

F7Chapter 9A (qualifying undertaxed profits tax).