154 Exclusion of qualifying intra-group financing arrangement expenses

154  Exclusion of qualifying intra-group financing arrangement expenses

(1)     Where—

(a)     the underlying profits of the member of a multinational group for an accounting period reflect expenses attributable to a qualifying intra-group financing arrangement that could be reasonably expected, over the expected duration of the arrangement, to—

(i)     increase the amount of expenses taken into account in calculating the member's underlying profits, and

(ii)     not result

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