Introduction Details of the Section
2.Subsection (1) describes when the section applies. This is where section 80 or 81 applies to a company for an accounting period, the “actual provision condition” is met, as defined in subsection (7) of section 82, and section 83 (cases where no taxable diverted profits arise) does not apply.
3.Subsection (2) explains how to determine the taxable diverted profits, in accordance with the provisions of subsection (2)(a), (b) and (c). It involves applying transfer pricing rules to the “material provision” (that is, the provision that has given rise to the “tax mismatch outcome”).