170 Adjustments for ultimate parent that is a flow-through entity

170  Adjustments for ultimate parent that is a flow-through entity

(1)     Where—

(a)     the ultimate parent of a multinational group is a flow-through entity, and

(b)     on determining its adjusted profits for an accounting period (ignoring this section), it has made a profit for that period,

those profits are to be further adjusted so as to exclude any amount of its profits that is qualifying.

(2)     An amount of profits is qualifying if—

(a)     it represents an amount of the ultimate parent's profits to which the holder of [a direct ownership interest] in the ultimate parent is entitled as a result of that interest, and

(b)     condition A, B or C is met.

[(2A)     Where profits are allocated to the ultimate parent as a result of section 168 (underlying profits of transparent and reverse hybrid entities), those profits are to be regarded, for the purposes of this section, as profits to which holders of ownership interests in the ultimate parent are entitled

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