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Contents

Legislation
Finance (No. 2) Act 2023
  • Introduction
  • Part 1 Income tax, corporation tax and capital gains tax
  • Part 2 Alcohol Duty
  • Part 3 Multinational top-up tax
  • Part 4 Domestic top-up tax
  • Part 5 Electricity generator levy
  • Part 6 Other taxes
  • Part 7 Miscellaneous and final
  • Schedule 1 Relief for research and development
  • Schedule 2 Estates in administration and trusts
  • Schedule 3 Corporate interest restriction etc.
  • Schedule 4 Investment vehicles
  • Schedule 5 Records relating to transfer pricing
  • Schedule 6 Categories of alcoholic products: interpretation
  • Schedule 7 Rates of alcohol duty
  • Schedule 8 Qualifying draught products: reduced rates
  • Schedule 9 Small producer alcoholic products: duty discount
  • Schedule 10 Penalties for contraventions of alcohol wholesaling provisions
  • Schedule 11 Alcohol duty: reviews and appeals
  • Schedule 12 Alcohol duty: duty stamps
  • Schedule 13 Alcohol duty: minor and consequential amendments
  • Schedule 14 Administration of multinational top-up tax
  • Schedule 15 Multinational top-up tax: elections
  • Schedule 16 Multinational top-up tax: transitional provision
  • Schedule 16A Multinational top-up tax: safe harbours
  • Schedule 17 Index of expressions defined or explained in Parts 3 and 4
  • Schedule 18 Administration of domestic top-up tax
  • Schedule 19 Dumping, subsidisation and safeguarding remedies
  • Schedule 20 Bilateral safeguarding remedies
  • Schedule 21 Soft drinks industry levy: flavour concentrates
  • Schedule 22 Reforms of HGV road user levy
  • Schedule 23 Freeports and investment zones: consequential amendments
  • Schedule 24 Homes for Ukraine Sponsorship Scheme: exemptions from tax
  1. Finance (No. 2) Act 2023
  2. Multinational top-up tax: elections

Schedule 15 | Multinational top-up tax: elections

From legislation.gov.uk

(1)For the elections to which this paragraph applies, see—F1

(a)section 127(8);

(aa)section 141(7);F2

(b)section 161;

(c)section 162;

(d)section 164;

(e)section 165;

(f)section 166;

(g)section 187;

(h)section 213;

(i)section 214.

(2)An election to which this paragraph applies—

(a)must specify the first accounting period for which it is to have effect (“the first election period”),

(b)must be made no later than the date by which the information return or overseas return notification in respect of that period is due,

(c)must be included in an information return submitted to HMRC or a qualifying authority in respect of that period, and

(d)has effect for the first election period and each subsequent accounting period until the commencement of the first accounting period for which a revocation of the election has effect.

(3)A revocation of an election to which this paragraph applies is to be made by the filing member of a multinational group and—

(a)must specify the first accounting period for which it is to have effect,

(b)must be made no later than the date by which the information return or overseas return notification in respect of that period is due, and

(c)must be included in an information return submitted to HMRC or a qualifying authority in respect of that period.

(4)But a revocation of an election to which this paragraph applies may not be made that has effect for the first election period or any of the next 4 accounting periods.

(5)Where an election to which this paragraph applies has been revoked, no further election of the same type may be made that has effect for the first accounting period for which the revocation has effect or any of the next 4 accounting periods.

(1)For the elections to which this paragraph applies, see—F3

(za)RepealedF4

(a)section 186;

(b)section 163;

(c)section 182(8);

(d)section 189;

(e)RepealedF5

(ea)section 199;F6

(f)section 205;

(fa)section 216;F7

(g)section 217(8);

(h)section 221(4);

(ha)section 229F;F8

(i)paragraph 2(9) of Schedule 16;

(j)paragraph 3 of Schedule 16;

(k)paragraph 14 of Schedule 16;F9

(l)paragraph 1 of Schedule 16A.F10

(2)An election to which this paragraph applies—

(a)must specify the accounting period for which it is to have effect,

(b)must be made no later than the date by which the information return or overseas return notification in respect of that period is due, and

(c)must be included in an information return submitted to HMRC or a qualifying authority in respect of that period.

Notes

  1. F1

    Words in Sch. 15 para. 1(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 50, 53(5)-(13)

  2. F2

    Sch. 15 para. 1(1)(aa) inserted (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. 58(2)(a)

  3. F3

    Words in Sch. 15 para. 2(1) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 50, 53(5)-(13)

  4. F4

    Sch. 15 para. 2(1)(za) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 24, 72(3)(a)

  5. F5

    Sch. 15 para. 2(1)(e) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 48(2), 72(1)(c)

  6. F6

    Sch. 15 para. 2(1)(ea) inserted (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. 58(2)(b)(i)

  7. F7

    Sch. 15 para. 2(1)(fa) inserted (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. 58(2)(b)(ii)

  8. F8

    Sch. 15 para. 2(1)(ha) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 9(2), 10

  9. F9

    Sch. 15 para. 2(1)(k) inserted (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. 40(2)

  10. F10

    Sch. 15 para. 2(1)(l) inserted (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(4)

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