183 Qualifying foreign tax credits (substitute loss carry forward assets)

183  Qualifying foreign tax credits (substitute loss carry forward assets)

(1)     A qualifying foreign tax credit of a member of a multinational group is to be included in the member's total deferred tax adjustment amount.

(2)     A foreign tax credit is qualifying if—

(a)     the territory in which the member is located—

(i)     requires that domestic losses are offset against relevant foreign income before foreign tax credits

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