Section 176A | Meaning of “non-marketable transferable tax credits” ^F1

(1)Sections 176B and 176C make provision about “non-marketable transferable tax credits”.

(2)A tax credit held by a member of a multinational group that is the originator of the credit is a non-marketable transferable tax credit if—

(a)it may be transferred to another person or entity, and

(b)it is neither a marketable transferable tax credit nor a qualifying refundable tax credit.

(3)A tax credit held by a member of a multinational group as a purchaser of the credit is a non-marketable transferable tax credit if it is neither a marketable transferable tax credit nor a qualifying refundable tax credit.

(4)In this section and in sections 176B and 176C “originator” and “purchaser” are to be construed in accordance with section 148A(1)(a).