Part 3Multinational top-up tax
Chapter 9Special provision for investment entities, joint venture groups and minority-owned members
Minority owned members
228Minority owned members
(1)
For the purposes of this Part, a member of a multinational group is a “minority owned member” if—
(a)
the ultimate parent holds no more than 30% of the ownership interests in that member, and
(b)
the member is not an investment entity.
(2)
If—
(a)
a minority owned member (“M”) holds (directly or indirectly) ownership interests in another minority owned member, and
(b)
no other minority owned member holds (directly or indirectly) ownership interests in M,
M is the minority owned parent of a minority subgroup, and the minority owned members in which M has ownership interests are also members of that group.
(3)
For the purpose of determining the effective tax rate and top-up amounts of members of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to members of that subgroup.
(4)
For the purposes of determining the effective tax rate and top-up amounts of a minority owned member that is not a member of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to that member.
F1(5)
But neither subsection (3) nor (4) applies to the reference to “standard member” in section 199(2A) (election to treat top-up amounts of relevant members as nil).