Part 3

Multinational top-up tax
Chapter 5

Covered tax balance

Amount of covered taxes

Amounts excluded from qualifying current tax expense
175
1
The amounts referred to in subsection (2) are to be excluded from a member of a multinational group’s qualifying current tax expense (to the extent they would otherwise be included).
2
Those amounts are as follows—
a
any amount that relates to income or gains that are not included in the member’s adjusted profits;
b
any amount that relates to an uncertain tax position;
c
any amount of credit or refund in respect of a qualifying refundable tax credit , or in respect of a marketable transferable tax credit, that is recorded as a reduction of qualifying current tax expense;
d
any amount that is not expected to be paid before the end of the period of three years commencing with the first day after the end of the accounting period;
e
any amount allocated to another member of the multinational group in accordance with this Part;
f
any amount excluded under section 180(3)(b) (blended CFC regime).
Words in s. 175(2)(c) inserted (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(4)
Words in s. 175 heading substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 19, 72(3)(a)