For the latest New Development, see ND.2684.
A nine-step process is in place to determine whether a group member has a top-up amount for an accounting period and, if so, the extent of it1.
Calculating top-up amounts—step 1
The first step is to determine the total top-up amount for the accounting period for the territory in which the member in question is located, using the multi-stage process outlined below2.
Calculate the effective tax rate
The effective tax rate is calculated for each jurisdiction, so adjusted profits and covered tax balances are pooled together for all group members in each territory. The aggregate covered tax balance (see D4.305) is divided by the aggregate adjusted profits (see D4.304) to give the effective tax rate for the territory.
If the effective tax rate is above 15% then no further calculations are required and the top-up amount is nil. This will need to be monitored for future accounting periods, or as a result of any prior year adjustments that arise.
If the result
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:29