185 Inclusion of existing deferred tax assets and liabilities on entry into regime

185  Inclusion of existing deferred tax assets and liabilities on entry into regime

(1)     This section applies to deferred tax assets and deferred tax liabilities of a member of a multinational group as at the beginning of the first accounting period for which Pillar Two rules apply to it that is reflected in its underlying profits accounts (and the adjustments set out in this section apply instead of those set out in section 182(2) to (7)).

(2)     Each such asset and liability is to be taken into account in determining the member's deferred tax expense—

(a)     if the nominal tax rate in relation to the asset [or liability]—

(i)     is less than 15%

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