Section 122 | Chargeable persons

(1)A person is chargeable to multinational top-up tax for an accounting period of a multinational group if the group is a qualifying multinational group in that period and—

(a)the person—

(i)is a ... member of the multinational group at any time in that period,^F1

(ii)is a body corporate or a partnership ..., and^F2

(iii)is located in the United Kingdom, or

(b)the person is chargeable to tax in respect of an entity that is a ... member of the multinational group at any time in that period.^F1

(2)A person is chargeable to tax in respect of a ... member of a multinational group if—^F3

(a)the profits of the ... member would, on the relevant assumptions, be the profits of the person for the purposes of income tax or corporation tax,^F3

(b)the ... member is located in the United Kingdom, and^F3

(c)the ... member is not—^F3

(i)a body corporate, or

(ii)a partnership ....^F4

(3)The relevant assumptions are—

(a)that the ... member has profits that are chargeable to income tax or corporation tax, and^F5

(b)that the person is resident in the United Kingdom for the purposes of that tax.

(4)Repealed^F6

(5)Repealed^F6

(6)Repealed^F6

(7)Where more than one person is chargeable to tax in relation to the same ... member of a qualifying multinational group as a result of the application of subsection (2), each of those persons is jointly and severally liable to multinational top-up tax.^F7