(1) In this section -
'disallowed accrual' means -
(a) any movement in deferred tax expense accrued in the financial accounts of a constituent entity which relates to an uncertain tax position, and
(b) any movement in deferred tax expense accrued in the financial accounts of a constituent entity which relates to distributions from a constituent entity;
'recapture exception accrual' means an amount of tax expense accrued in the financial accounts of a constituent entity that is attributable to changes in associated deferred tax liabilities in respect of -
(a) cost recovery allowances on tangible assets,
(b) the cost of a licence or similar arrangement from a government for the use of immovable property or exploitation of natural resources which entails significant investment in tangible assets,
(c) research and development expenses,
(d) de-commissioning and remediation expenses,
(e) fair value accounting on unrealised net gains,
(f) foreign currency exchange net gains,
(g) insurance res
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