Section 175 | Amounts excluded from qualifying current tax expense

(1)The amounts referred to in subsection (2) are to be excluded from a member of a multinational group’s qualifying current tax expense (to the extent they would otherwise be included).

(2)Those amounts are as follows—

(a)any amount that relates to income or gains that are not included in the member’s adjusted profits;

(b)any amount that relates to an uncertain tax position;

(c)any amount of credit or refund in respect of a qualifying refundable tax credit , or in respect of a marketable transferable tax credit, that is recorded as a reduction of qualifying current tax expense;^F1

(d)any amount that is not expected to be paid before the end of the period of three years commencing with the first day after the end of the accounting period;

(e)any amount allocated to another member of the multinational group in accordance with this Part;

(f)any amount excluded under section 180(3)(b) (blended CFC regime).

(3)The reference in subsection (2)(a) to income or gains that are not included in the member’s adjusted profits does not include any income or gains that are not included in its adjusted profits solely because of an election under section 164 (intra-group transactions).^F2