[176D Tax credits etc allocated under tax equity partnerships]
Finance (No 2) Act 2023 (2023 c 30) | Legislation

[Tax equity partnerships]

[176D  Tax credits etc allocated under tax equity partnerships]

[(1)     Where—

(a)     a member of a multinational group is an investor in a tax equity partnership arrangement, and

(b)     an election under section 165 (excluded equity gains and losses included) applies in relation to the member for an accounting period,

qualifying flow-through tax benefits provided to the member under that arrangement in that period are to be excluded from the covered tax balance of that member for that period.

(2)     “Flow-through tax benefits” means tax credits, other than qualifying refundable tax credits, and the value of amounts of tax deductible losses made available to be used by an investor in a tax equity partnership arrangement under that arrangement (whether or not those credits or losses are used by the investor).

(3)     Section 176E (proportional amortisation method) applies for the purposes of determining the extent to which flow-through tax benefits are “qualifying” where—

(a)     in determining

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