Part 3Multinational top-up tax

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

Adjusted profits of a member of a multinational group

133Adjusted profits of a member of a multinational group

(1)

For the purposes of this Part, references to the adjusted profits of a member of a multinational group are to the underlying profits of that member adjusted in accordance with this Chapter and (to the extent applicable) Chapter 8.

(2)

Sections 134 to 137 set out how to determine the underlying profits.

(3)

Sections 138 to 158 set out various adjustments that may need to be made to those profits.

(4)

Sections 159 and 160 set out adjustments to be made in relation to members that are permanent establishments.

(5)

Sections 161 to 164 make provision for elections for certain matters to be calculated in an alternative manner.

(6)

Sections 167 to 171 set out adjustments in relation to transparent and hybrid entities and entities subject to a “qualifying dividend regime”.

(7)

Other provisions of this Part may require further adjustments of underlying profits, including provision in—

(a)

Chapter 9 (investment entities), and

(b)

Schedule 16 (transitional provision).