[183A Alternative to section 183 where carry forward of credits not permitted]

[183A  Alternative to section 183 where carry forward of credits not permitted]

[(1)     A special foreign tax asset of a member of a multinational group is to be used to increase its covered tax balance in accordance with this section.

(2)     Subsection (3) applies where—

(a)     the territory in which a member of a multinational group is located requires that domestic losses are offset against relevant foreign income before foreign tax credits can be applied against tax on foreign income,

(b)     the territory limits

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