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Schedules

Schedule 16U.K.Multinational top-up tax: transitional provision

Part 2U.K.Transitional safe harbour

Chapter 2U.K.Application [F1of Chapter 1] to joint ventures etc

Textual Amendments

F1Words in Sch. 16 Pt. 2 Ch. 2 heading inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(3), 10

Application in the case of joint venture groupU.K.

10 [F2(1)] For the purpose of applying Chapter 1 of this Part of this Schedule to a joint venture group (see [F3section 227] which applies this Schedule generally, with modifications, to joint venture groups) [F4, that Chapter has effect as if]

(a)paragraph [F53(2)(b)] were omitted (requirement for qualifying country-by-country report),

(b)the reference in paragraph 4(2) to “the financial accounts of that member that are used for preparation of the group’s country-by-country report” were to the financial accounts that would be used if a qualifying country-by-country report had been prepared in respect of the joint venture group, and

(c)in paragraph 9(2), the words from “ignoring” to the end were omitted.

[F6(2)For that purpose ignore section 227(1)(a) (reference to ultimate parent treated as reference to joint venture parent).

(3)Accordingly, the filing member of a multinational group may make a separate transitional safe harbour election in respect of joint venture members of a joint venture group in a territory.]

Textual Amendments

F2Sch. 16 para. 10 renumbered as Sch. 16 para. 10(1) (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. 58(3)(a)

F3Words in Sch. 16 para. 10(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. 58(3)(b)(i)

F4Words in Sch. 16 para. 10(1) inserted (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. 58(3)(b)(ii)

F5Word in Sch. 16 para. 10(1)(a) 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. 58(3)(c)

F6Sch. 16 para. 10(2)(3) inserted (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. 58(3)(d)

Application to investment entities in same territory as ownersU.K.

11(1)Subsection (2) applies where—

(a)an investment entity that is a member of a multinational group, and

(b)all of the members of a multinational group with direct ownership interests in it,

are located in the same territory.

(2)The investment entity is to be treated as a standard member of that group for the purposes of this Part of this Schedule.

Minority owned membersU.K.

12For the purposes of this Part of this Schedule, references to the standard members of a multinational group include minority owned members.