Section 138 | Profits adjusted to be before tax

(1)The underlying profits of a member of a multinational group for an accounting period are to be adjusted by adding back any debit, and excluding any credit, for tax expense amounts reflected in ... those profits.^F1

(2)In this Part “tax expense amount” means an amount of tax expense (including a deferred tax expense) in respect of—

(a)a covered tax (whether or not the income to which the tax relates are excluded from adjusted profits for the purposes of this Part);

(b)multinational top-up tax, or any tax equivalent to multinational top-up tax;

(c)a qualifying domestic top-up tax (see section 256);

(d)a qualifying undertaxed profits tax (see section 257);

(e)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;

(f)a disqualified refundable imputation tax (see section 253).