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Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

Pension expense

7For section 147 (accrued pension expense) substitute—

147Accrued pension expense

(1)This section applies in an accounting period where a member of a multinational group—

(a)has made contributions to a pension fund in the period,

(b)has received amounts from the pension fund in the period, or

(c)otherwise has amounts of income or expense relating to the pension fund reflected in its underlying profits.

(2)Take the amount of income or expense (expressed as a negative number where expense) that has arisen directly in respect of the fund as reflected in the member’s underlying profits and—

(a)add the sum of contributions made to the fund by the member in the period, and

(b)subtract any amount received by the member from the fund in the period.

(3)If the result of subsection (2)—

(a)is more than nil, reduce the underlying profits by that result, or

(b)is less than nil, increase the underlying profits by that result (as expressed a positive number).