Part 3Multinational top-up tax

Chapter 4Calculation of adjusted profits of members of a multinational group

Adjustments of underlying profits

139Profits adjusted to be profits before consolidation adjustments to eliminate intragroup transactions

1

The underlying profits of a member of a multinational group are to be adjusted so that they include income, expenses, gains and losses arising from transactions between that member and other members of that group.

2

Subsection (1) is subject to—

a

section 137 (amounts outside profit and loss excluded), and

b

section 164 (where an election is made under that section to exclude profits from intra-group transactions).