Multinational Top-up Tax and Domestic Top-up Tax

MTT21000 - Calculating the effective tax rate: Adjusted profits: Contents

The adjusted profits of a member are the underlying profits after certain adjustments have been made.

See MTT21010 for guidance on determining the underlying profits.

See MTT21100 for guidance on adjustments that must be made to those underlying profits.

This is set out in Section 133 of Finance (No.2) Act 2023.

1. MTT21010

   The underlying profits
2. MTT21020

   Wholly domestic groups - Alternative basis for determining underlying profits
3. MTT21100

   Adjustment of underlying profits
4. MTT21110

   Tax expense
5. MTT21120

   Intra-group transactions
6. MTT21125

   Intra-group transactions – Permanent differences arising from transfer pricing adjustments
7. MTT21130

   Relevant share acquisition adjustments
8. MTT21140

   Excluded dividends
9. MTT21150

   Excluded equity gain or loss
10. MTT21160

    Revaluation method gain or loss
11. MTT21170

    Asymmetric foreign currency gain or loss
12. MTT21180

    Illegal payments
13. MTT21190

    Fines and penalties
14. MTT21200

    Prior period errors
15. MTT21210

    Changes in accounting principles
16. MTT21220

    Pension fund expense
17. MTT21230

    Transactions requiring arm's length treatment
18. MTT21240

    Intra-group financing arrangements
19. MTT21250

    Election to use realisation principle
20. MTT21260

    Stock-based compensation election
21. MTT21270

    Election to spread certain capital gains over five years
22. MTT21280

    Currency hedging election
23. MTT21290

    Election where assets and liabilities adjusted to fair value for tax purposes
24. MTT21300

    Qualifying tier one capital
25. MTT21400

    Tax credits - Overview
26. MTT21410

    Qualifying refundable tax credits
27. MTT21420

    Marketable transferable tax credits
28. MTT21430

    Marketable transferable tax credits – Adjustments required
29. MTT21440

    Non-marketable transferable tax credits