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Legislation
Finance (No. 2) Act 2023

Crossheading Investment entities

  • Section 220 Top-up amount of investment entity
  • Section 221 Substance based income exclusion for investment entity
  • Section 222 Investment entity effective tax rate
  • Section 223 Adjustments
  • Section 224 Additional top-up amounts of investment entities
  • Section 225 Attribution of top-up amounts and additional top-up amounts to responsible member
  1. Investment entities
  2. Investment entity effective tax rate

Section 222 | Investment entity effective tax rate

From legislation.gov.uk

The investment entity effective tax rate in a territory for an accounting period is determined by taking the following steps—F1

Step 1Determine the adjusted profits made by each of the investment entities in the territory, as determined under Chapter 4 and adjusted under section 223.

Step 2Subtract the sum of the losses of those investment entities that made a loss in that period from the sum of the profits of those investment entities that made a profit in that period.

Step 3If the result of Step 2 is nil or less, the investment entity effective tax rate is to be treated as 15%. Otherwise, proceed to Step 4.

Step 4Determine the covered tax balance of each such investment entity in accordance with Chapter 5.

Step 5Adjust the amounts determined in Step 4 in accordance with section 223 (to the extent applicable).

Step 6Add together the amounts determined in Step 5 that are adjusted positive covered tax balances.

Step 7Add together the amounts determined in Step 5 that are adjusted negative covered tax balances.

Step 8Subtract the result of Step 7 from the result of Step 6.

Step 9Divide the result of Step 8 by the result of Step 2. This is the investment entity effective tax rate.

Notes

  1. F1

    Words in s. 222 substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 67, 72(4)

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