Part 3Multinational top-up tax

Chapter 4Calculation of adjusted profits of members of a multinational group

Adjustments of underlying profits

138Profits adjusted to be before tax

1

The underlying profits of a member of a multinational group for an accounting period are to be adjusted by adding back any debit, and excluding any credit, for tax expense amounts reflected in its those profits.

2

In this Part “tax expense amount” means an amount of tax expense (including a deferred tax expense) in respect of—

a

a covered tax (whether or not the income to which the tax relates are excluded from adjusted profits for the purposes of this Part);

b

multinational top-up tax, or any tax equivalent to multinational top-up tax;

c

a qualifying domestic top-up tax (see section 256);

d

a qualifying undertaxed profits tax (see section 257);

e

taxes accrued by an insurance company in respect of returns to policyholders to the extent that section 152(2) applies in relation to those taxes;

f

a disqualified refundable imputation tax (see section 253).