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

MTT25000 · Calculating the effective tax rate: Covered tax balance

  • MTT25010 · Calculating the covered tax balance
  • MTT25100 · Covered taxes
  • MTT25200 · Amounts to be excluded
  • MTT25210 · Amounts to be included
  • MTT25220 · Intra-group distributions
  • MTT25230 · Refundable imputation tax
  • MTT25300 · Post-filing adjustment of covered taxes
  • MTT25310 · Post-filing adjustment of covered taxes - Effect of rate changes to deferred tax expense
  • MTT25320 · Recalculation where covered taxes not paid
  • MTT25400 · Non-marketable transferable tax credits
  • MTT25500 · Controlled foreign company regimes
  • MTT25510 · Blended CFC regimes
  • MTT25511 · Blended CFC regimes - Applicable ETR of a CFC entity
  • MTT25520 · Allocation of current taxes under cross-crediting regime
  • MTT25600 · Carry-forward of negative covered tax balance where there is an adjusted profit
  • MTT27000 · Deferred tax
  1. Calculating the effective tax rate: Covered tax balance: Contents
  2. Calculating the effective tax rate: Covered tax balance: Refundable imputation tax

MTT25230 | Calculating the effective tax rate: Covered tax balance: Refundable imputation tax

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

An amount of tax that is disqualified refundable imputation tax will not be regarded as covered tax and must be excluded from the covered tax balance, in accordance with section 173(2)(d) of Finance (No.2) Act 2023.

A refundable tax credit that arises in respect of a refundable imputation tax (whether qualified or disqualified) will not be a qualifying refundable tax credit, in accordance with section 148(3) of the Act. See MTT21410 for guidance on qualifying refundable tax credits.

The meanings of ‘disqualified refundable imputation tax’ and ‘qualified refundable imputation tax’ are set out in section 253(1) and (2) of the Act.

See MTT18010 for guidance on determining the location of an entity.

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