Part 3Multinational top-up tax

Chapter 5Covered tax balance

Amount of covered taxes

175Amounts excluded from covered tax balance

1

The amounts referred to in subsection (2) are to be excluded from a member of a multinational group’s qualifying current tax expense (to the extent they would otherwise be included).

2

Those amounts are as follows—

a

any amount that relates to income or gains that are not included in the member’s adjusted profits;

b

any amount that relates to an uncertain tax position;

c

any amount of credit or refund in respect of a qualifying refundable tax credit that is recorded as a reduction of qualifying current tax expense;

d

any amount that is not expected to be paid before the end of the period of three years commencing with the first day after the end of the accounting period;

e

any amount allocated to another member of the multinational group in accordance with this Part;

f

any amount excluded under section 180(3)(b) (blended CFC regime).