144 Adjustments for asymmetric foreign currency income and losses

144  Adjustments for asymmetric foreign currency income and losses

(1)     This section only applies in relation to a member of a multinational group where its accounting currency and its tax currency are different.

(2)     Where—

(a)     the member has a gain or a loss as a result of fluctuations in the exchange rate between its accounting currency and its tax currency, and

(b)     the gain or loss is reflected differently in its taxable income and in the determination of its underlying profits (including where it

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