Part 3

Multinational top-up tax
Chapter 9

Special provision for investment entities, joint venture groups and minority-owned members

Investment entities

Attribution of top-up amounts and additional top-up amounts to responsible member
225
1
In this section “top-up amount” includes an additional top-up amount determined under section 224.
2
Section 200 applies to the attribution of a top-up amount of a member of a multinational group that is an investment entity (“the relevant member”) to a responsible member as it applies to a top-up amount of any other member of the group.
3
Section 201 applies for the purpose of determining the inclusion ratio of the responsible member, but—
a
in carrying out Step 1 in section 201(1)—
i
the adjusted profits of the entity determined in that Step are to be further adjusted in accordance with section 223 (to the extent applicable);
ii
if an election under section 214 (taxable distribution method election) has been made in relation to the entity, the adjusted profits of the entity are to be treated as including the undistributed income amount for the entity determined under section 215, and
b
subsection (4) of that section applies whether or not the relevant member is a flow-through entity (so that entities that are not members of the group are always ignored).