Finance (No. 2) Act 2023 (c. 30)

Part 3 Multinational top-up tax

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

Adjustments of underlying profits

139 Profits 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).