[273B Effect of becoming subject to Pillar Two rules]

[273B  Effect of becoming subject to Pillar Two rules]

[(1)     This section applies where the Pillar Two rules did not apply to a qualifying entity for one or more accounting periods (each a “pre-Pillar Two period”).

(2)     Where—

(a)     the entity has a recaptured deferred tax liability arising as a result of section 184 (recaptured deferred tax liabilities),

(b)     the initial period, in relation to that liability, is a pre-Pillar Two period, and

(c)     the first accounting period in which the Pillar Two rules apply to the entity is earlier than the sixth accounting period

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