[148A Transferable tax credits]
Finance (No 2) Act 2023 (2023 c 30) | Legislation

[148A  Transferable tax credits]

[(1)     A tax credit is a transferable tax credit in relation to a member of a multinational group if—

(a)     the member is—

(i)     the person to whom the credit was originally granted (“the originator”), or

(ii)     a person (“a purchaser”) who has acquired the credit (whether from the originator or anyone else), and

(b)     the transferability condition is met in relation to the member.

(2)     A transferable tax credit is a marketable transferable tax credit in relation to a member of a multinational group if—

(a)     it is a transferable tax credit, and

(b)     the marketable condition is met in relation to the member.

(3)     Those conditions are met differently depending on whether the member is the originator or a purchaser.

(4)     The transferability condition is met—

(a)     in relation to the originator if, under the law of the territory in which the credit was granted, credits

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