Section 229I | Joint ventures ^F1

(1)This section applies where—

(a)the ultimate parent of a multinational group is not subject to Pillar Two IIR tax for an accounting period,

(b)the group includes a joint venture group, and

(c)the members of the joint venture group are undertaxed in relation to the multinational group for that period.

(2)The members of a joint venture group are undertaxed in relation to a multinational group if—

(a)the sum of amounts attributed to responsible members of the multinational group under Chapter 7 in respect of members of the joint venture group’s top-up amount and additional top-up amounts, is less than

(b)the sum of such amounts in respect of the joint venture group that would be attributed under that Chapter to the ultimate parent of the multinational group if it were subject to Pillar Two IIR tax.

(3)The amount given by subtracting the amounts mentioned in paragraph (a) of subsection (2) from the amounts mentioned in paragraph (b) of that subsection is an untaxed amount of the joint venture group in relation to the multinational group.

(4)Sections 229C to 229F (allocation of untaxed amounts) apply for the purposes of allocating an untaxed amount of a joint venture group in relation to a multinational group to qualifying members of that multinational group as they apply to the allocation of an untaxed amount of a member of the multinational group to those members.