Regulation 38

any amount of current tax expense that relates to income or gains that are excluded from the computation of the GloBE income or loss of the constituent entity for the financial year;

any amount of current tax expense that relates to an uncertain tax position for the constituent entity for the financial year;

any reduction of current tax expense made in respect of a qualified refundable tax credit or in respect of a marketable transferable tax credit;

any amount of current tax expense that is not expected to be paid by the constituent entity before the end of the period of 3 years commencing on the first day after the end of the financial year;

any amount of current tax expense that relates to a gain or loss in respect of the disposal of local tangible assets (as defined in regulation 32(6)) in the financial year for which an election in regulation 32(1) is made for the constituent entity;

any amount of credit (whether refundable or not) or refund for the constituent entity for the financial year, in respect of covered taxes, that —

is not a qualified refundable tax credit or a marketable transferable tax credit; and

has not been taken into account in the qualifying current tax expense for the constituent entity for that financial year or a previous financial year;

any amount of credit (other than one mentioned in sub‑paragraph (f)) or refund in respect of a tax credit that is not a qualified refundable tax credit or a marketable transferrable tax credit; and

any current tax expense for a previous financial year.

after any liability to covered taxes has been reduced or discharged by it; or

in the absence of any tax liability to covered taxes.