Finance Act 2024

Transitional safe harbour

39 (1) Part 2 of Schedule 16 (transitional safe harbour) is amended as follows.

(2) In paragraph 3, for sub-paragraph (1) substitute—

“(1) The filing member of a multinational group may make a transitional safe harbour election for an accounting period in respect of a territory.

(1A) The effect of the election is that all of the standard members of the group located in the territory are to be treated as not having top-up amounts or additional top-up amounts for the purpose of determining the liability of any member of the group to multinational top-up tax.”

(3) In paragraph 4—

(a) in sub-paragraph (3)—

(i) omit the “and” after paragraph (b), and

(ii) after paragraph (c) insert “, and

(d) qualified substance based income amount (see paragraph 9(2)).”, and

(b) in sub-paragraph (5), in the words before paragraph (a), for “(c)” substitute “(d)”.

(4) In paragraph 6(6), for “if” substitute “unless”.