Article 31 - Additions to and Reductions in Covered Taxes

For the purposes of applying the provisions of Clause 1 of Article 30 of these Regulations, additions to Covered Taxes of a Constituent Entity for the Fiscal Year shall include all of the following where applicable:

1. Any amount of Covered Taxes accrued as an expense in the profit before taxation in the financial accounts of the Constituent Entity.

2. Any amount of Constituent Entity Loss Deferred Tax Asset that has been used by the Constituent Entity under the provisions of Article 35 of these Regulations.

3. Any amount of Covered Taxes that is paid in the Fiscal Year and that relates to an uncertain tax position where that amount has been treated for a previous Fiscal Year as a reduction to Covered Taxes under Paragraph B of this Article.

4. Any amount of credit or refund in respect of a Qualified Refundable Tax Credit that is recorded as a reduction to the current tax expense.

For the purposes of applying the provisions of Clause 1 of Article 30 of these Regulations, the reductions to Covered Taxes of a Constituent Entity for the Fiscal Year is the sum of any of the following:

1. The amount of current tax expense with respect to income excluded from the computation of Constituent Entity Income or Loss except when the Constituent Entity is a Pension Fund and the current expense relates to a pension surplus.

2. Any amount of credit or refund in respect of a Non-Qualified Refundable Tax Credits that is not recorded as a reduction to the current tax expense.

3. Any amount of tax refund or credit, except for a Qualified Refundable Tax Credit or Marketable Transferable Tax Credit, that is not included in the current tax expense in the financial accounts.

4. The amount of current tax expense which relates to an uncertain tax position.

5. Any amount of current tax expense that is not expected to be paid within three years of the last day of the Fiscal Year.

6. The amount received by the originator of a non-marketable transferable tax credit in exchange for the credit.

7. Any excess received by the purchaser of the face value of a non-marketable transferable tax credit over its purchase price in proportion to the amount of the credit used to satisfy its liability for a Covered Tax.

8. The amount of any gain received by the purchaser on the transfer of a non-marketable transferrable tax credit provided the transfer occurs during the Fiscal Year concerned.