Finance (No. 2) Act 2023

[^key-bf8b5c5621b442458b1b09968e329fa7]: S. 180(8)(aa)(ab) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(b), 72(4)

[^key-952c8fca8ad78a8bca5e35ee664de26b]: Words in s. 180(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(a), 72(4)

[^key-0b813b12603ad75186bf7cf63a20384b]: Words in s. 180(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(c)(i), 72(4)

[^key-d22f924228a476a4b66caf47fc0f5f84]: Words in s. 180(8)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 25(2)(c)(ii), 72(4)

[^key-16fc988d87afc93800f456f3a92ec2d2]: S. 183(6)(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(b), 72(4)

[^key-3c8bdba8c565bf4d17d6b2e18747334c]: Words in s. 183(5) renumbered as s. 183(5)(a) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(a)(i), 72(4)

[^key-14bb5b8a4c15d727e11613d36db69b04]: S. 183(5)(b) and word inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 29(a)(ii), 72(4)

[^key-543117e161509e2d01307bc5996b7f05]: S. 184(5)-(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 30, 72(4)

[^key-77000bf5c4b0d8310f52aa170aa468da]: S. 185(8)(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 31, 72(4)

[^key-d411be6f2ccde5e70be7b015eec6ba08]: S. 195(8)(9) substituted for s. 195(8) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 32, 72(4)

[^key-ea8bbd54d6d992fef6ee33f51c9af9bd]: S. 195(2) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(1), 72(1)(c)

[^key-207e71224b01fe51d09738cb6988408f]: S. 195(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(1), 72(1)(c)

[^key-cbd1960df1fc54a453824d0c83184459]: S. 196(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 34, 72(4)

[^key-0d7f4a301e9f43c12cafb5d0ccf54c98]: S. 196(1)(b) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 36(a), 72(4)

[^key-cfbb7541e62b32038f3b9567c68389a7]: Words in s. 196(3)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 36(b), 72(4)

[^key-7b05e627fc888851f74efd1a8c7b0799]: S. 197(10) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 35, 72(4)

[^key-53841e8a52334c5e1d185a1a2023c0b3]: Word in s. 197(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 12(2)(a), 72(4)

[^key-b15d64f5c63ab3e1d3b2b2a0cea091d7]: Words in s. 197(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 12(2)(b), 72(4)

[^key-10d52f778c3c9b5de958099e4033b77f]: S. 199(2A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(c), 72(4)

[^key-c38cb213772f6aeacd7ca92ae0cc943a]: Words in s. 199 heading substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(d), 72(4)

[^key-4ef07108a06a114d8b938475dbee5fa9]: Words in s. 199(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(a)(i), 72(4)

[^key-f7af8bd5dae1d10dfcb681e9d4e7b1b6]: Word in s. 199(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(a)(ii), 72(4)

[^key-c7a61701793185c173d59df9b5d64c77]: Word in s. 199(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4)

[^key-c92530af9eb0bda5d98baff3beae3dcf]: Word in s. 199(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4)

[^key-9691fb50b13e23d2f6e4f61ec7fd1137]: Word in s. 199(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4)

[^key-5f0ae98b952ef31be390c67d7f90bb70]: Word in s. 199(6)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4)

[^key-546ee4b7a407fa02e35a627092a256f6]: Word in s. 199(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(1)(b), 72(4)

[^key-d6a41c3dec27919ee1052a84bf77c113]: Words in s. 201(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 49(2), 72(4)

[^key-edb1b0d47fc22c30e777f36af22529f8]: S. 201(4) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 49(3), 72(4)

[^key-11dfe4bacf2a1e9c65689d462e23c8d3]: Words in s. 203(4)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4)

[^key-471331a8f9f5d0e2ca0afa79a3318886]: Words in s. 203(5)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4)

[^key-4b6d495c781f15c6393096c37b1577cc]: Words in s. 203(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4)

[^key-4dea6a919a9249b205a612bcb43ddce9]: Words in s. 203(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 37, 72(4)

[^key-c6abf0bae9772137ca7752f2bf5c3f35]: S. 206(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(10), 72(4)

[^key-b5a1b14779b8d7bebca0cf582f156caa]: Words in s. 206(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(2)(a), 72(4)

[^key-8a955057c459de818a24077b1ccf1b0d]: Word in s. 206(1)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(2)(b), 72(4)

[^key-1e9fbfe6aa56fa054ed5a040e7eea523]: Words in s. 206(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(3)(a), 72(4)

[^key-d3167b24c64b07b22cff64d37cfee06d]: Words in s. 206(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(a), 72(4)

[^key-620b50e748c705bb89f683ddd9e37b31]: Words in s. 206(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(b), 72(4)

[^key-dd429668e8f06727e6e2626209f39a79]: Word in s. 206(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(c)(i), 72(4)

[^key-8935e01bc27408b15b2bd227961e45e0]: Words in s. 206(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(4)(c)(ii), 72(4)

[^key-9de2505b20a0c8b7b267536b99f077fa]: Words in s. 206(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(5)(a), 72(4)

[^key-55088fd97cd2abdcb71f419c0a2ee9ed]: Words in s. 206(4) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(5)(b), 72(4)

[^key-61d774f1e7cc8e5ec1e190ae8e762381]: Word in s. 206(5)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(a)(i), 72(4)

[^key-1be6f4711c36262404fa172a4eb7b6eb]: Word in s. 206(5)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(a)(ii), 72(4)

[^key-96e7de7097abb7d36550e0ad7d544c8b]: Words in s. 206(5)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(b), 72(4)

[^key-ab59ce0e6566d2cbf0d523e62fa118b4]: Words in s. 206(5)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(6)(c), 72(4)

[^key-7148b036982a57ed45af42e5e7614d4a]: Word in s. 206(6)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(a)(i), 72(4)

[^key-a25728a675f07e47618e58f6592a8232]: Word in s. 206(6)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(a)(ii), 72(4)

[^key-3e77dbdee0523d8061f6b06e2a265a8a]: Words in s. 206(6)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(b), 72(4)

[^key-5ac3660b850ded2e355bff0cde0d9da9]: Words in s. 206(6)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(7)(c), 72(4)

[^key-15a60ecf1fadffac10a9d90ff18ce440]: Word in s. 206(7)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(i), 72(4)

[^key-1a865c3bc0d1fda1dfa0541ec944f623]: Word in s. 206(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(ii), 72(4)

[^key-e1c3efcf3993ece1034a8cc127c0cc81]: Words in s. 206(7)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(a)(iii), 72(4)

[^key-a4a35bc81406f19b87f45d570bc8f46e]: Words in s. 206(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(b)(i), 72(4)

[^key-a0bcb4a9b396131d1502b1aabcdc6a19]: Words in s. 206(7)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(8)(b)(ii), 72(4)

[^key-459eab57fb1e64e720b896b7e3062a8c]: Word in s. 206(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(a)(i), 72(4)

[^key-4da59fc1c885bcc74fd4d81feea5c74f]: Words in s. 206(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(a)(ii), 72(4)

[^key-33cb4da8e7e951616c6907b28195599b]: Words in s. 206(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(b)(i), 72(4)

[^key-f199c6db10ca1e17c8b1835c70f79985]: Words in s. 206(8)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(b)(ii), 72(4)

[^key-8daf1e62a09d309197e55ab034b71aa5]: Word in s. 206(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(3)(b), 72(4)

[^key-8d4eb0c8f1baf4a8355a11cb37f6fadf]: Words in s. 206(8) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 38(9)(c), 72(4)

[^key-4c18a1ebf8be70adaa32fef38e379d0f]: S. 211(5) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 60(b), 72(4)

[^key-ae010c346b48390816b63a5e22ab416f]: Word in s. 211(2) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 60(a)(i), 72(4)

[^key-c04807c44fe674f51ad84ef0715a16f1]: S. 211(2)(ba) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 60(a)(ii), 72(4)

[^key-e43b4486c543b013495115708763e572]: Words in s. 212(4) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 61, 72(4)

[^key-8ec063e6cc79076f936260a79506d8ce]: Words in s. 215(2)(c) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 62, 72(4)

[^key-85d8f4794aab5516b5be1c7b1c6aac2c]: Words in s. 216(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 63, 72(4)

[^key-71baebae8e67894ae6f4f7a3c57feb65]: S. 217(1A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 64, 72(4)

[^key-552014183e4b851f63cd3a160d33b311]: S. 217(8)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 65, 72(4)

[^key-7b0e535b4ef7df064b24ca2863d62ac6]: S. 220(1) Step 9 inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 66(a)(ii), 72(1)(f)

[^key-19ae8d198ce7ac5ce114e4d968534d58]: S. 220(2) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 66(b), 72(1)(f)

[^key-89d482e67ce116b62f1d5bf6164ff8eb]: Words in s. 220(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 66(a)(i), 72(1)(f)

[^key-34f8caf8093f27dd1522668568bab0e1]: Words in s. 222 substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 67, 72(4)

[^key-7bfb6e41b307fa513de467c92e70ae67]: Words in s. 223(7) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(c), 72(4)

[^key-3ffe24c47e76593885ee5022478a2b3d]: Words in s. 223(7)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(a), 72(4)

[^key-b79a0d764dabfe19d244df37b913db30]: Word in s. 223(7)(b) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(2)(b), 72(4)

[^key-9f1392a6fa5ba9eb2e262d92ace9294a]: Words in s. 223(8) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(3)(b), 72(4)

[^key-9c80ef2489f619e67b4ab5d933bebc7d]: Words in s. 223(8)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(3)(a), 72(4)

[^key-b1fcee2e48c8f1c788092ae2ee094c8c]: Words in s. 223(9) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 50(4), 72(4)

[^key-ba7d9cdabbd1143d28efbc2449956475]: Words in s. 226(2) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(a), 72(3)(b)

[^key-c4789a2bd1382fcf0d37d0e28054ab17]: Words in s. 226(2)(a) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(b), 72(3)(b)

[^key-26bed0b396124d45411a30814c2feb5e]: Words in s. 226(2)(b) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(c), 72(3)(b)

[^key-7f4252016c1736209a235eda742e63de]: Words in s. 226(2)(c) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(d), 72(1)(b)

[^key-b05a6b7fcce0a835e520ce50baa609b8]: Words in s. 226(2)(f) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(e), 72(4)

[^key-ce69afa3afd42443902683e9e6fbf4a8]: Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(i), 72(4)

[^key-db95ee69fde4364c2a79b41c745f319e]: Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(ii), 72(4)

[^key-0b912db138d720a4981ae9562c41d37b]: Words in s. 227(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(iii), 72(4)

[^key-4ca3308622cf8c703933ec203683fe70]: Words in s. 227(1)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(b), 72(4)

[^key-b0cfa3c49752ecbb6ffe49b550acbfed]: Words in s. 227(2) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(3), 72(4)

[^key-67e1317180a711fcf5be725b7af26f99]: Words in s. 227(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(a), 72(4)

[^key-fe113a117c1682e2acdb7a40cb61985b]: Words in s. 227(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(b), 72(4)

[^key-ed8488eda190d2b5fcd0d8ab653ccee9]: S. 228(5) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(2), 72(4)

[^key-8c5bf05034e091f68908931df25e35cb]: Words in s. 240(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 17(a), 72(4)

[^key-c1663023b3f8b534d209a989e41d9879]: Words in s. 240(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 17(b), 72(4)

[^key-82ccd3f7bbdf51b9ed2093170e4e737a]: S. 241(1A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(b), 72(1)(d)

[^key-bff9fb4cbca319e88d93e965caeb571d]: S. 241(2A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(d), 72(1)(d)

[^key-30f46c326af55ca148eeab2ae27e1798]: Words in s. 241(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(a), 72(1)(d)

[^key-09d7f79595bdeb9ae8fa867632349050]: Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 8, 10

[^key-1eed0a0331c6d58e63081df680fa8b04]: Words in s. 241(2) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(i), 72(1)(d)

[^key-7f9ffcfa76dedb1d79abbc49f8b0c9f3]: Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(ii), 72(1)(d)

[^key-9098ca6ddbba9ff85ba4aa7155ad0cbd]: Word in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(i), 72(1)(d)

[^key-003890ac86b46b295c352badb3b7d7c0]: Word in s. 241(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(ii), 72(1)(d)

[^key-170cfafe434627db675fb43081c6ad0c]: Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iii), 72(1)(d)

[^key-3b493d37be38d4ffca3fc9b62607c0e1]: Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iv), 72(1)(d)

[^key-c7f74e41e0828f4db67c68c6a7c93dbe]: Word in s. 242(5)(a) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 68, 72(4)

[^key-53b1f491083c517962e0ccfe0767f78d]: Words in s. 254(4) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(3), 10

[^key-799c79a4d2bfdcd78cc834944811d3da]: Words in s. 255(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 69, 72(4)

[^key-299400037cc8e14d76a826df4e0e8ffd]: S. 256(1A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(b), 72(1)(d)

[^key-daeae748bf77a8f7da0cb51c764c2ab0]: S. 256(2A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(d), 72(1)(d)

[^key-6fa8695c8ea7f4b7c24b68ba169ec016]: Words in s. 256(1)(b) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(a), 72(1)(d)

[^key-98a72ab19776995520689ffeb5365c29]: Words in s. 256(2) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(c)(i), 72(1)(d)

[^key-46d43a96a4980ca3962894f139c8b061]: Words in s. 256(2) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(c)(ii), 72(1)(d)

[^key-ab7502178e941b1f188d33028a252661]: Word in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(i), 72(1)(d)

[^key-e1637d888594ead044d63a11ba5ecfff]: Word in s. 256(4) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(ii), 72(1)(d)

[^key-d3295ee24ecd356b18892b0304671abc]: Words in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(iii), 72(1)(d)

[^key-724e50d23f3a96ce4c88127071b4cf9e]: Words in s. 256(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(2)(e)(iv), 72(1)(d)

[^key-a2f644efc837a206ebd292bbbd0ac9b6]: Words in s. 257(1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 7(2), 10

[^key-5cc2f8dad1869813e6dc3243ea50b980]: S. 266(1A)(1B) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 41(3), 72(4)

[^key-a8d0983de068d500beae8737aa608fee]: Words in s. 266(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 41(2), 72(4)

[^key-7559a0c6aa9ebd036f2d97dbc4a924c4]: S. 267(3ZA) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 44, 72(4)

[^key-66ea56fd9c3f144aca716b207d05e252]: S. 270(A1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(2), 72(4)

[^key-edb3368bbc20f7248fc055d0ad79db4d]: Words in s. 270(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(3)(a), 72(4)

[^key-45a13cbb56d65e945de492318e8de210]: Words in s. 270(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 42(3)(b), 72(4)

[^key-d7fd836ae6384249a068299f6191dd35]: S. 272(3A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 43(2), 72(4)

[^key-c84562f239612b48a9106c4ecda45512]: S. 272(4)(c) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(3), 10

[^key-70003a668900cffca8709af04b7a2c31]: S. 272(8)(e) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 43(3), 72(4)

[^key-e15aedde02ad57574165636922689849]: S. 273(4)(z1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(4), 10

[^key-912d709a187de0203008919b95fd18a7]: S. 349(2)(fa) inserted (20.3.2025) by Finance Act 2025 (c. 8), s. 82(a)

[^key-2878436c4c0aa17d01e4c60d20eaaaeb]: Word in s. 349(2)(g) substituted (20.3.2025) by Finance Act 2025 (c. 8), s. 82(b)

[^key-43eebb7b254aa907a433fcb23ab21cc4]: Word in Sch. 14 para. 2(12) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 70(a), 72(4)

[^key-8a5b9753fa7fc2c58b0e2206c2257e5f]: Words in Sch. 14 para. 7(6) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 70(b), 72(4)

[^key-7e3a98ee2c703e0d699d532f7ef94afa]: Sch. 14 para. 10(12) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(2), 72(1)(e)

[^key-a9483d2f7765218bacb06e0eeec30ba3]: Sch. 14 para. 13(11) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(3), 72(1)(e)

[^key-12f90f930054167b83bae444b0be1ae6]: Sch. 14 para. 32(3A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 52(4), 72(1)(e)

[^key-f32df2b8cac49cd69109260cc545c9a8]: Sch. 15 para. 2(1)(ha) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(2), 10

[^key-c686a0a4838580bac4770ddeb571e2b5]: Sch. 15 para. 2(1)(za) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 24, 72(3)(a)

[^key-87e55072bc9491b0dc7a3213e62eaf9c]: Sch. 15 para. 2(1)(e) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(2), 72(1)(c)

[^key-880480427d4c7334e53c9d7c8b11c862]: Sch. 16 para. 3(7A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(d), 72(4)

[^key-ab99e0a4780a5384266cb012922ac3f5]: Sch. 16 para. 3(10) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(e), 72(4)

[^key-bfc493c1cfa72f5749dfad6139844a04]: Words in Sch. 16 para. 3(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(a), 72(4)

[^key-857db596179eddf093682b78c2020f8f]: Words in Sch. 16 para. 3(2)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(b), 72(4)

[^key-6185d2b2bc5777a55d59aec1492ff6e6]: Words in Sch. 16 para. 3(7) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(2)(c), 72(4)

[^key-507e03592285e83f16080f30fbb03f74]: Sch. 16 para. 4(1A) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(4), 72(4)

[^key-cd35d78075d8f7c679cfda75d83da5b2]: Word in Sch. 16 para. 4(1)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(a)(i), 72(4)

[^key-517d1d71316a1c626e9a06b3f1d3e26c]: Words in Sch. 16 para. 4(1)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(a)(ii), 72(4)

[^key-52a25eca86cfaca8b586fad2784451d8]: Sch. 16 para. 4(1)(b) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(3)(b), 72(4)

[^key-488983e35312500a27838e9da07447e5]: Word in Sch. 16 para. 4(3)(d) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(5), 72(4)

[^key-99c3911ca8c616577832f0c20572cb7e]: Words in Sch. 16 para. 4(4) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 47(3), 72(2)

[^key-46f62ba2c8c1e9365495b182f9290ca8]: Sch. 16 para. 5 renumbered as Sch. 16 para. 5(1) (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(7)(a), 72(4)

[^key-04bb16e606399d845df59ab9fcf884c7]: Sch. 16 para. 5(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 46(7)(b), 72(4)

[^key-c710f91bc26987eed55d6e09c775a58c]: Words in Sch. 16A para. 1(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(i), 72(1)(d)

[^key-9357691abaa289202baf8d0ee837da3f]: Word in Sch. 16A para. 1(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(ii), 72(1)(d)

[^key-c6a769bffb9046f57639dc8a919363b5]: Sch. 16A para. 1(3)(ba) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(a)(iii), 72(1)(d)

[^key-5990b8ca8e3411a684aaec2d5b803ab5]: Sch. 16A para. 2(1A)-(1C) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(b)(iii), 72(1)(d)

[^key-4c9950615c3046de592500e4f4bb8ff5]: Words in Sch. 16A para. 2(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(3)(b)(ii), 72(1)(d)

[^key-c52d8be7de0529be75b323f13851b359]: Words in Sch. 16A para. 4(1)(b) omitted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 71, 72(4)

[^key-6cbcc7a51c04bd243283c6fc65f151c4]: Sch. 12 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(1)(4) (with s. 64(5)(6))

[^key-4fefde1256dcdad30746a449a0d18cc0]: S. 112 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(1)(4) (with s. 64(5)(6))

[^key-73822d15d7c52e1802159a47097b8c8d]: Words in s. 119(5) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(ii)(4) (with s. 64(5)(6))

[^key-394a1906f2535d9aa04afc6d9e3aac67]: Words in s. 119(8)(a) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(ii)(4) (with s. 64(5)(6))

[^key-16e236f61d69af99c1b240922ad3a4dd]: S. 119(4) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(d)(i)(4) (with s. 64(5)(6))

[^key-af2ac6efa01944315bd308aa040455d6]: Sch. 11 para. 1(4) omitted (1.5.2025) by virtue of Finance Act 2025 (c. 8), s. 64(2)(e)(4) (with s. 64(5)(6))

[^M_F_fb443a29-0737-44ac-ff7e-3d66f9e842ce]: Sch. 13 para. 9 repealed (1.5.2025) by Finance Act 2025 (c. 8), s. 64(2)(f)(4) (with s. 64(5)(6))

First-year allowance for expenditure on electric vehicle charge points

Relief for research and development

Treatment of profits from patents etc: small profits rate of corporation tax

Energy (oil and gas) profits levy: de-carbonisation allowance

Museums and galleries exhibition tax relief: extension of sunset date

Extension of the temporary increase in theatre tax credit etc

Seed enterprise investment scheme: increase of limits etc.

CSOP schemes: share value limit and share class

Enterprise management incentives: restricted shares and declarations

Certain lump sums to be taxed at marginal rate

Money purchase annual allowance

Annual allowance: tapering

Collective money purchase arrangements

Relief relating to net pay arrangements

Payments under Jobs Growth Wales Plus

Power to clarify tax treatment of devolved social security benefits

Qualifying care relief: increase in individual’s limit

Estates in administration and trusts

Transfer of basic life assurance and general annuity business

Certain re-insurance sums not to count as deemed I-E receipts

Insurers in difficulties: write-down orders for corporation tax purposes

Insurers in difficulties: write-down orders in case of pension schemes

Corporate interest restriction

Investment vehicles

Share exchanges involving non-UK incorporated close companies

Records relating to transfer pricing

Double taxation relief: foreign nominal rates

Payments to farmers under the lump sum exit scheme etc

Contracts completed after ordinary notification period

Separated spouses and civil partners

Carried interest: election to pay tax as scheme profits arise

Relief on disposal of joint interests in land

Alcoholic strength

Small producer alcoholic products

Charge on exceptional generation receipts

Chargeable persons

Amount charged by reference to “top-up amounts”

How to calculate top-up amounts and attribute them

Administration of multinational top-up tax

Meaning of “multinational group” and “ultimate parent”

Excluded entities

Responsible members

Qualifying multinational groups

Whether de-merged groups meet the revenue threshold

Effective tax rate

Adjusted profits of a member of a multinational group

Underlying profits as determined for statements of ultimate parent

Underlying profits accounts

No amounts outside of profit and loss account to be included

Profits adjusted to be profits before consolidation adjustments to eliminate intragroup transactions

147A

• (1) The underlying profits of a member of a multinational group, and the covered tax balance of that member (see Chapter 5), are to be adjusted (if necessary) to secure that—

• (a) qualifying refundable tax credits are accounted for as income rather than as tax expense,

• (b) tax credits that are marketable transferable tax credits in relation to the member are accounted for as income rather than as tax expense, and

• (c) other tax credits are accounted for as tax expense rather than as income.

• (2) Section 148 sets out when tax credits are qualifying refundable tax credits.

• (3) Section 148A sets out the meaning of “transferable tax credit” and “marketable transferable tax credit”.

• (4) Sections 148B and 148C set out rules about the value of marketable transferable tax credits.

• (5) Sections 176A to 176C (in Chapter 5) set out rules about the value of tax credits that are not marketable transferable tax credits but which are transferable or were transferred (and which as a result of subsection (1)(c) are generally to be accounted for as tax expense).

• (6) See also sections 176D to 176F which contain special rules for tax credits received in under a tax equity partnership arrangement.

148A

• (1) A tax credit is a transferable tax credit in relation to a member of a multinational group if—

• (a) the member is—

• (i) the person to whom the credit was originally granted (“the originator”), or

• (ii) a person (“a purchaser”) who has acquired the credit (whether from the originator or anyone else), and

• (b) the transferability condition is met in relation to the member.

• (2) A transferable tax credit is a marketable transferable tax credit in relation to a member of a multinational group if—

• (a) it is a transferable tax credit, and

• (b) the marketable condition is met in relation to the member.

• (3) Those conditions are met differently depending on whether the member is the originator or a purchaser.

• (4) The transferability condition is met—

• (a) in relation to the originator if, under the law of the territory in which the credit was granted, credits of that type may be transferred to a person or entity that is not connected with originator before the end of 15 months after the end of the accounting period in which the credit is granted, and

• (b) in relation to a purchaser if, under the law of that territory, credits of that type may be transferred to a person or entity that is not connected with the purchaser—

• (i) under the same or similar conditions as would apply to the originator, and

• (ii) before the end of the accounting period in which it was transferred to the purchaser.

• (5) The marketable condition is met—

• (a) in relation to the originator, if—

• (i) the credit is transferred to a person or entity that is not connected with the originator in the period beginning with the day on which the credit was granted and ending 15 months after the end of the accounting period in which the credit was granted at a price equal to or in excess of 80% of its net present value, or

• (ii) similar credits are traded between persons or entities that are not connected to each other in that period, and are typically traded at a price equal to or in excess of 80% of their net present value, and

• (b) in relation to a purchaser, if the purchaser acquired the credit from a person or entity that is not connected to the purchaser at a price equal to or in excess of 80% of its net present value.

• (6) Subsections (7) and (8) apply for the purposes of determining the net present value of a tax credit.

• (7) In making that determination, assume that the entity that holds it will be able to use it in the accounting periods in which it may be used.

• (8) The discount rate to be used in making that determination is to be determined by reference to the return on debt instruments that are issued by the government of the territory in which the credit was granted—

• (a) that have—

• (i) the same, or a similar, maturity to the period over which the credit is to be used, or

• (ii) in a case in which the credit is to be used over a period exceeding 5 years, a maturity of 5 years, and

• (b) that are issued—

• (i) in relation to a credit that has been transferred, in the accounting period in which the credit was transferred, or

• (ii) in relation to a credit held that has not been transferred, in the accounting period in which it was granted.

• (9) References in subsections (6) and (8) to an accounting period are—

• (a) in relation to determining net present value in connection with determining whether the marketable condition is met by the originator, an accounting period of the originator, and

• (b) in relation to determining net present value in connection with determining whether the marketable condition is met by a purchaser, an accounting period of the purchaser.

• (10) Where a transferable tax credit is also a qualifying refundable tax credit, it is to be treated as not being a transferable tax credit for the purposes of this Part.

148B

• (1) The underlying profits of a member of a multinational group that is the originator in relation to a marketable transferable tax credit are to be adjusted to secure that the value of marketable transferable tax credits it holds, and has held, as originator are reflected as follows.

• (2) Where the credit is not transferred before the end of 15 months after the end of the accounting period in which it was granted, the full value of the credit is to be recognised as income.

• (3) Where the credit is subsequently transferred for consideration which is less than the value of the credit, the difference between the value of the credit and the consideration received for its transfer is to be recognised as a loss in the accounting period in which it is transferred.

• (4) Where the credit is transferred before the end of 15 months after the end of the accounting period in which the credit is granted, the consideration for the transfer (rather than the value of the credit) is to be recognised as income.

• (5) Where the credit has not been transferred, and was not fully used, before its expiry, the value of so much of the credit as has not been used is to be reflected as a loss in the accounting period in which the credit expired.

148C

• (1) The underlying profits of a member of a multinational group that is the purchaser in relation to a marketable transferable tax credit are to be adjusted to secure that the value of marketable transferable tax credits it holds, and has held, as purchaser are reflected as follows.

• (2) On using an amount of the credit in an accounting period, the amount given by subsection (3) is to be recognised as income.

• (3) That amount is the amount given by multiplying—

• (a) the amount used divided by the full value of the credit, by

• (b) the amount given by subtracting the purchase price of the credit from the full value of the credit.

• (4) On transferring the credit, the amount in subsection (5) is to be reflected in the underlying profits for the accounting period in which the transfer occurred—

• (a) if positive, as a gain, or

• (b) if negative, as a loss.

• (5) That amount is the amount given by subtracting—

• (a) the sum of—

• (i) the purchase price of the credit, and

• (ii) any amounts recognised as income in accordance with subsection (2) (whether in that accounting period or a previous accounting period), from

• (b) the sum of—

• (i) the amount of the credit that has been used, and

• (ii) the consideration for the transfer.

• (6) Where the credit has not been transferred, and was not fully used, before its expiry, the amount in subsection (7) is to be reflected as a loss in the accounting period in which the credit expired.

• (7) That amount is the amount given by subtracting—

• (a) the amount of the credit that was used, from

• (b) the sum of the purchase price of the credit and any amounts recognised in accordance with subsection (2).

Attribution of losses between permanent establishment and main entity

Election to use realisation principle

Election to reflect deductions for stock-based compensation

Election to exclude intra-group transactions

Election in relation to hedging currency risk in ownership interests

Underlying profits of hybrids