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Official guidance
Multinational Top-up Tax and Domestic Top-up Tax

MTT21000 · Calculating the effective tax rate: Adjusted profits

  • MTT21010 · The underlying profits
  • MTT21020 · Wholly domestic groups - Alternative basis for determining underlying profits
  • MTT21100 · Adjustment of underlying profits
  • MTT21110 · Tax expense
  • MTT21120 · Intra-group transactions
  • MTT21125 · Intra-group transactions – Permanent differences arising from transfer pricing adjustments
  • MTT21130 · Relevant share acquisition adjustments
  • MTT21140 · Excluded dividends
  • MTT21150 · Excluded equity gain or loss
  • MTT21160 · Revaluation method gain or loss
  • MTT21170 · Asymmetric foreign currency gain or loss
  • MTT21180 · Illegal payments
  • MTT21190 · Fines and penalties
  • MTT21200 · Prior period errors
  • MTT21210 · Changes in accounting principles
  • MTT21220 · Pension fund expense
  • MTT21230 · Transactions requiring arm's length treatment
  • MTT21240 · Intra-group financing arrangements
  • MTT21250 · Election to use realisation principle
  • MTT21260 · Stock-based compensation election
  • MTT21270 · Election to spread certain capital gains over five years
  • MTT21280 · Currency hedging election
  • MTT21290 · Election where assets and liabilities adjusted to fair value for tax purposes
  • MTT21300 · Qualifying tier one capital
  • MTT21400 · Tax credits - Overview
  • MTT21410 · Qualifying refundable tax credits
  • MTT21420 · Marketable transferable tax credits
  • MTT21430 · Marketable transferable tax credits – Adjustments required
  • MTT21440 · Non-marketable transferable tax credits
  1. Calculating the effective tax rate: Adjusted profits: Contents
  2. Calculating the effective tax rate: Adjusted profits: Tax expense

MTT21110 | Calculating the effective tax rate: Adjusted profits: Tax expense

From HM Revenue & Customs · Multinational Top-up Tax and Domestic Top-up Tax

Tax expense amounts should not be reflected in a member’s adjusted profits, in accordance with section 138 of Finance (No.2) Act 2023.

Underlying profits should therefore be adjusted to add back debits and exclude credits, where they relate to a tax expense amount.

A ‘tax expense amount’ is an amount of tax expense (including a deferred tax expense) in respect of the following types of tax:

  • a covered tax (whether or not the income to which the tax relates is excluded from the adjusted profits)

  • MTT, or any equivalent tax (see MTT09970 for qualifying taxes)

  • a qualifying domestic top-up tax

  • a qualifying undertaxed profits tax

  • taxes accrued by an insurance company in respect of returns to policyholders, to the extent that section 152(2) applies in relation to those taxes (see MTT45430)

  • a disqualified refundable imputation tax (see MTT25230)

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