LJ 3Meaning of foreign income tax

1. For the purposes of this Part, foreign income tax—

2. means—
   1. an amount of a tax of another country meeting the requirements of section YA 2(5) (Meaning of income tax varied):
   2. in relation to a double tax agreement providing relief from tax or double taxation, an amount of tax to which the double tax agreement applies; and
3. includes an amount of a tax of another country that is either or both of the following:
   1. a qualified domestic minimum top-up tax, as defined in Article 10.1.1 of the global anti-base erosion model rules:
   2. of substantially the same nature as multinational top-up tax payable because of the application of the modifications to Article 2.1 of the global anti-base erosion model rules set out in schedule 25B, item 1B (Items modifying global anti-base erosion model rules); and
5. does not include an amount of a tax of another country that is based on—
   1. Articles 2.1 to 2.3 of the global anti-base erosion model rules; or
   2. Articles 2.4 to 2.6 of those model rules.