Part 3Multinational top-up tax

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

Adjustments of underlying profits

153Exclusion of certain insurance reserve movement expense

1

The underlying profits of a member of a multinational group that is an insurance company are to be adjusted so as to exclude any expense resulting from the movement of its insurance reserves where the movement is economically matched by excluded dividends (ignoring the extent to which those dividends also reflect any investment management fees).

2

The underlying profits of a member of a multinational group that is an insurance company are to be adjusted so as to exclude any expense resulting from the movement of its insurance reserves where the movement is economically matched by an excluded equity gain or loss.