Part 3Multinational top-up tax
Chapter 5Covered tax balance
F1Transferable tax credits
Annotations:
Amendments (Textual)
176AMeaning of “non-marketable transferable tax credits”
1
Sections 176B and 176C make provision about “non-marketable transferable tax credits”.
2
A tax credit held by a member of a multinational group that is the originator of the credit is a non-marketable transferable tax credit if—
a
it may be transferred to another person or entity, and
b
it is neither a marketable transferable tax credit nor a qualifying refundable tax credit.
3
A tax credit held by a member of a multinational group as a purchaser of the credit is a non-marketable transferable tax credit if it is neither a marketable transferable tax credit nor a qualifying refundable tax credit.
4
In this section and in sections 176B and 176C “originator” and “purchaser” are to be construed in accordance with section 148A(1)(a).
Ss. 176A-176C and cross-heading inserted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 8(6)