Part 3Multinational top-up tax
Chapter 4Calculation of adjusted profits of members of a multinational group
Adjustments of underlying profits
147AF1Treatment of tax credits
1
The underlying profits of a member of a multinational group, and the covered tax balance of that member (see Chapter 5), are to be adjusted (if necessary) to secure that—
a
qualifying refundable tax credits are accounted for as income rather than as tax expense,
b
tax credits that are marketable transferable tax credits in relation to the member are accounted for as income rather than as tax expense, and
c
other tax credits are accounted for as tax expense rather than as income.
2
Section 148 sets out when tax credits are qualifying refundable tax credits.
3
Section 148A sets out the meaning of “transferable tax credit” and “marketable transferable tax credit”.
4
Sections 148B and 148C set out rules about the value of marketable transferable tax credits.
5
Sections 176A to 176C (in Chapter 5) set out rules about the value of tax credits that are not marketable transferable tax credits but which are transferable or were transferred (and which as a result of subsection (1)(c) are generally to be accounted for as tax expense).
6
See also sections 176D to 176F which contain special rules for tax credits received in under a tax equity partnership arrangement.