124 How to calculate top-up amounts and attribute them

124  How to calculate top-up amounts and attribute them

(1)     Generally, a member of a multinational group in a territory will have a top-up amount for an accounting period if—

(a)     the effective tax rate of the members of the group in that territory for that period is less than 15%, and

(b)     that member has profits for that period.

(2)     Chapter 3 of this Part sets out how to determine the effective tax

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