MTT10110 | Scope: Definitions: Definitions of 'multinational group' and 'ultimate parent'

The definitions of multinational group and ultimate parent are set out in section 126 of Finance (No.2) Act 2023.

Multinational group

A consolidated group is a multinational group if it includes at least one member not located in the same territory as the others.

Consolidated group

A consolidated group consists of its members, which are:

• the ultimate parent,

• the entities whose assets, liabilities, income, expenses and cash flows are included in the consolidated financial statements of the ultimate parent, and

• entities that have not been included in the consolidated financial statements due to size, materiality or because the entity is held for sale.

Where the group is qualifying (see MTT11000+), all of these entities will be in scope of MTT, except for those that are excluded entities (see MTT10210).

Ultimate parent

An ultimate parent is an entity:

• in which no other entity has a controlling interest (see MTT17030), and

• which has a controlling interest in one or more other entities.

Stateless members

A stateless member, which is a member that is not located in any territory, is treated as being located in a nominal territory containing only that member.

A group that consisted solely of a number of entities located in a single territory and one stateless member would therefore be a multinational group.