Joint venture groupU.K.
226Joint venture groupU.K.
(1)For the purposes of this Part “joint venture group” means a joint venture parent of a qualifying multinational group and its joint venture subsidiaries (together its “members”).
(2)An entity is a joint venture parent of a multinational group [F1for an accounting period of that entity] if—
(a)the financial results of that entity [F2for all or any part of that period] are reported under the equity method in the consolidated financial statements of the ultimate parent of that group,
(b)the ultimate parent holds at least 50% of the ownership interests in the entity [F3at any time in that period],
(c)the entity is not the ultimate parent of a [F4multinational group that meets condition A in section 129(2) for that accounting period (revenue threshold exceeded in at least 2 of previous 4 accounting periods)],
(d)the entity is not an excluded entity,
(e)the entity is not an entity owned by an excluded entity—
(i)that only carries out activities that are ancillary to the activities of the excluded entity,
(ii)whose activities consist, wholly or almost wholly, of the holding of assets or the investment of funds for the benefit of the excluded entity, or
(iii)whose income is, wholly or almost wholly, excluded dividends or excluded equity gains (or a mixture of both),
(f)the multinational group [F5referred to in paragraph (a)] is not composed exclusively of excluded entities, and
(g)the entity is not a joint venture subsidiary in relation to another joint venture parent.
(3)An entity is a joint venture subsidiary of a joint venture parent if its assets liabilities, income, expenses and cash flows are included in the consolidated financial statements of the joint venture parent.
(4)Where the main entity of a permanent establishment is a joint venture parent of a multinational group or a joint venture subsidiary, that permanent establishment is to be treated as a separate joint venture subsidiary of the same multinational group joint venture group.
Textual Amendments
F1Words in s. 226(2) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(a), 72(3)(b)
F2Words in s. 226(2)(a) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(b), 72(3)(b)
F3Words in s. 226(2)(b) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(c), 72(3)(b)
F4Words in s. 226(2)(c) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(d), 72(1)(b)
F5Words in s. 226(2)(f) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 39(e), 72(4)
227Application of Part to joint venture groupsU.K.
(1)This Part applies to a joint venture group as it applies to a multinational group, but [F6in their application by virtue of this subsection] Chapters 3 to 6 and 8 of this Part [F7, this Chapter other than this section and section 226] and [F8Schedules 16 and 16A] [F9have effect] as if—
(a)references to the ultimate parent were to the joint venture parent of that group,
(b)references to a member of a multinational group were to the members of the joint venture group, and.
(c)references to the filing member were to the filing member of [F10each respective multinational] group whose ultimate parent holds at least 50% of the ownership interests in the joint venture parent.
(2)For the purposes of the other provisions of this [F11Part (in its application by virtue of subsection (1)),] the members of the joint venture group are treated as members of [F12each multinational group] whose ultimate parent directly or indirectly holds at least 50% of the ownership interests in the joint venture parent.
(3)But [F13(in the application of this Part by virtue of subsection (1))] no member of the joint venture group is to be regarded as an intermediate parent member or a partially owned parent member of [F14the joint venture] group.
Textual Amendments
F6Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(i), 72(4)
F7Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(ii), 72(4)
F8Words in s. 227(1) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(2)
F9Words in s. 227(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(iii), 72(4)
F10Words in s. 227(1)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(b), 72(4)
F11Words in s. 227(2) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(3), 72(4)
F12Words in s. 227(2) substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 30
F13Words in s. 227(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(a), 72(4)
F14Words in s. 227(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(b), 72(4)