Schedules
Schedule 12Pillar Two
Part 2Multinational top-up tax
4Charging permanent establishments of intermediate/partially-owned parent members
1
Section 128 (responsible members) is amended as follows.
2
In subsection (3), for paragraph (c) substitute—
c
at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.
3
In subsection (4), after “for” insert
—
a
every permanent establishment for which it is the main entity, and
b
4
In subsection (5), for paragraph (b) substitute—
b
at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.
5
In subsection (6), after “for” insert
—
a
every permanent establishment for which it is the main entity, and
b
6
In section 232, after subsection (3) insert—
3A
But an entity with a permanent establishment is not to be taken as having ownership interests in that permanent establishment.