Part 3

Multinational top-up tax
Chapter 9

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

Joint venture group

Application of Part to joint venture groups
227
1
This Part applies to a joint venture group as it applies to a multinational group, but in their application by virtue of this subsection Chapters 3 to 6 and 8 of this Part , this Chapter other than this section and section 226 and Schedules 16 and 16A have 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 each 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 Part (in its application by virtue of subsection (1)), the members of the joint venture group are treated as members of each multinational group whose ultimate parent directly or indirectly holds at least 50% of the ownership interests in the joint venture parent.
3
But (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 the joint venture group.
Words in s. 227(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. 41(2)
Words in s. 227(2) 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. 30
Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(i), 72(4)
Words in s. 227(1) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(ii), 72(4)
Words in s. 227(1) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(a)(iii), 72(4)
Words in s. 227(1)(c) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(2)(b), 72(4)
Words in s. 227(2) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(3), 72(4)
Words in s. 227(3) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(a), 72(4)
Words in s. 227(3) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 40(4)(b), 72(4)