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).