178 Reallocation of tax expense
Finance (No 2) Act 2023 (2023 c 30) | Legislation

178  Reallocation of tax expense

(1)     Where—

(a)     profits have been allocated to a member of a multinational group (“O”) under section 167 or 168 (allocation of profits of hybrid, transparent and reverse hybrid entities), and

(b)     the member from whom the profits have been allocated has an amount of qualifying current tax expense in respect of those profits,

that qualifying [current] tax expense is to be allocated to O.

[(1A)     Where—

(a)     a member of a multinational group has an amount of qualifying current tax expense,

(b)     that amount is in respect of profits not included in the member's underlying profits, and

(c)     if those profits had been included in the member's underlying profits, a corresponding amount of adjusted profits would have been allocated to another member of the group

Powered by Lexis+®
 

Popular documents

LEXISNEXIS

Schemes of arrangement—procedure

Schemes of arrangement—procedureProduced with input from Rebecca Cousin of Slaughter and May on market practice.This Practice Note looks at the detailed procedures to be followed to implement the acquisition by a buyer (offeror) of all the shares, or one or more classes of shares, in a company

LEXISNEXIS

What is electronic money?

What is electronic money?BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant

LEXISNEXIS

In a business-to-business contract where a contractual long-stop date has passed but the parties wish to

In a business-to-business contract where a contractual long-stop date has passed but the parties wish to continue with the contract, should they document their intention to continue or enter into a new contract?Long-stop dateAs stated in the Drafting Notes to clause: Long-stop date definition, the

LEXISNEXIS

Legal Services Board

Legal Services BoardThe Legal Services Board (LSB) is the single independent oversight regulator of the legal profession and sector in England and Wales. It does not directly regulate individual lawyers and, in most circumstances, will not directly regulate firms.Mandate and structureThe LSB is the