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Official guidance
Multinational Top-up Tax and Domestic Top-up Tax

MTT54000 · Administration: Payments and interest

  • MTT54010 · Overview
  • MTT54100 · Payment date and interest
  • MTT54110 · Allocating payments of Multinational Top-up Tax and Domestic Top-up Tax
  • MTT54200 · Group payment notices - Introduction
  • MTT54210 · Effect of a group payment notice
  • MTT54220 · Group payment notices - The notice, time limits, and scope
  • MTT54230 · Group payment notices - Ring-fenced entities
  • MTT54290 · Partnership payment notices
  • MTT54300 · Relief of overpaid tax
  • MTT54310 · Claiming relief of overpaid tax
  • MTT54320 · Excessive amount repaid by HMRC
  • MTT54400 · Effect of group payments and recovery of group payments
  • MTT54410 · Effect of partnership payments and recovery of partnership payments
  1. Administration: Payments and interest: Contents
  2. Administration: Payments and interest: Group payment notices - Ring-fenced entities

MTT54230 | Administration: Payments and interest: Group payment notices - Ring-fenced entities

From HM Revenue & Customs · Multinational Top-up Tax and Domestic Top-up Tax

A group payment notice can only be issued to a ring-fenced entity if the responsible member that was originally liable is also a member of the same ring-fenced body sub-group.

A ‘ring-fenced entity’ is a body corporate which is a ring-fenced body or a member of a ring-fenced body sub-group.

A ‘ring-fenced body sub-group' is a group of entities consisting of:

  • a ring-fenced body parent undertaking and its subsidiaries, or

  • a ring-fenced body, which is not a subsidiary of a ring-fenced body parent undertaking, and its subsidiaries.

In this context, a ring-fenced body has the same meaning as in section 142A of the Financial Services and Markets Act 2000, and a ring-fenced body parent undertaking is a body corporate subject to rules made under section 192JA of the same Act.

This is set out in paragraph 35, schedule 14 to Finance (No.2) Act 2023.

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