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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 credits - Overview

MTT21400 | Calculating the effective tax rate: Adjusted profits: Tax credits - Overview

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

The underlying profits of a member of a group and its covered tax balance (if necessary) need to be adjusted to ensure that qualifying refundable tax credits and marketable transferable tax credits are accounted for as income, rather than a tax expense.

See MTT21410 for the definition of qualifying refundable tax credits, and MTT21430 for the definition of marketable transferable tax credits.

Tax credits that are not marketable transferable tax credits or qualifying refundable tax credits are generally to be accounted for as a reduction to tax expense, rather than income (see MTT21440).

This is set out in Section 147A of Finance (No.2) Act 2023.

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