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Legislation
Finance (No. 2) Act 2023

Crossheading Allocation of untaxed amounts

  • Section 229C Allocation of untaxed amount to members
  • Section 229D Amount allocated to the United Kingdom
  • Section 229E Allocation to qualifying members
  • Section 229F Election to make one member of a group liable for untaxed amounts
  1. Allocation of untaxed amounts
  2. Allocation of untaxed amount to members

Section 229C | Allocation of untaxed amount to members F1

From legislation.gov.uk

(1)An untaxed amount of a member of a multinational group is to be allocated to qualifying members of the group located in the United Kingdom by—

(a)first, determining the amount (“the UK proportion”) of the untaxed amount to be allocated to the group in the United Kingdom in accordance with section 229D, and

(b)then, allocating an amount of the UK proportion to each qualifying member located in the United Kingdom in accordance with section 229E.

(2)But no allocation is to be made under subsection (1) if in section 229D(1) the results of both Step 2 and Step 5 are nil.

(3)For the purposes of this Chapter, a member of a multinational group is qualifying unless it is—

(a)an investment entity, ...F2

(b)a member of a joint venture group , orF3

(c)a securitisation company within the meaning of the Taxation of Securitisation Companies Regulations 2006 (S.I. 2006/3296).F3

Notes

  1. F1

    Pt. 3 Ch. 9A inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 5, 10

  2. F2

    Word in s. 229C(3)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 24(a), 53(5)-(13)

  3. F3

    S. 229C(3)(c) and word inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 24(b), 53(5)-(13)

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