Part 3Multinational top-up tax

Chapter 9Special provision for investment entities, joint venture groups and minority-owned members

Joint venture group

227Application of Part to joint venture groups

(1)

This Part applies to a joint venture group as it applies to a multinational group, but F1in their application by virtue of this subsection Chapters 3 to 6 and 8 of this Part F2, this Chapter other than this section and section 226 and F3Schedules 16 and 16A F4have 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 F5each 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 F6Part (in its application by virtue of subsection (1)), the members of the joint venture group are treated as members of F7each multinational group whose ultimate parent directly or indirectly holds at least 50% of the ownership interests in the joint venture parent.

(3)

But F8(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 F9the joint venture group.