Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

23Substance based income exclusion: impairment losses

In section 197(4)—

a

omit the “and” after paragraph (b), and

b

after paragraph (c) insert—

d

any impairment loss, and

e

so much of the reversal of a previous impairment loss as does not cause the carrying value to exceed the value it would have been had the impairment loss not been recognised,