203 Additional top-up amounts where covered taxes less than expected

203  Additional top-up amounts where covered taxes less than expected

(1)     This section applies in an accounting period in relation to standard members of a multinational group in a territory where—

(a)     those members have a collective loss for that period, and

(b)     the combined covered tax balance for those members for the current period is less than nil, and

(c)     the collective negative covered tax balance expressed as a positive number is greater than the amount given by multiplying the collective loss expressed as a positive number by 15% (“the expected covered tax amount”).

(2)     Where this section applies, those members in that territory collectively have an additional top-up amount (a “collective additional amount”)

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