Part 3

Multinational top-up tax
Chapter 4

Calculation of adjusted profits of members of a multinational group

Adjusted profits of a member of a multinational group

Adjusted profits of a member of a multinational group
133
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).