179 Controlled foreign company tax regimes
Finance (No 2) Act 2023 (2023 c 30) | Legislation

179  Controlled foreign company tax regimes

(1)     Where—

(a)     a member of a multinational group (“C”) is subject to a controlled foreign company tax regime, and

(b)     C has an ownership interest in another member of the group (“F”) that is a [CFC entity] in relation to C,

any amount of qualifying current tax expense included in C's underlying profits accounts with respect to tax on C's share of the profits of F are to be allocated to F (to the extent it has not already been allocated as a result of another provision of this Part).

[(1A)     Qualifying current tax expense allocated to F is to be regarded as qualifying current tax expense of F for the purposes of applying section 175(2)(a).]

(2)     But the amount of qualifying current tax expense in respect of mobile income allocated

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