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Legislation
Finance (No. 2) Act 2023

Crossheading Meaning of “entity” etc

  • Section 231 Meaning of entity
  • Section 232 Permanent establishments ...
  • Section 232ZA Legal main entity distinct from main entity
  • Section 232A Partnerships
  • Section 233 Treatment of protected cell companies
  • Section 234 Governmental, international and non-profit entities
  • Section 235 Pension funds and pension services entities
  • Section 236 Investment funds and investment entities
  • Section 237 Intermediate and partially-owned parent members
  • Section 238 Tax transparency of entities
  1. Meaning of “entity” etc
  2. Intermediate and partially-owned parent members

Section 237 | Intermediate and partially-owned parent members

From legislation.gov.uk

(1)A member of a multinational group is a partially-owned parent member of that group if—

(a)it is not a permanent establishment, investment entity or the ultimate parent,

(b)it has—F1

(i)a direct or indirect ownership interest in another member of the group, orF1

(ii)a permanent establishment, andF1

(c)more than 20% of the ownership interests that represent an entitlement to a share of the profits of the member are held by persons that are not members of the group.

(2)A member of a multinational group is an intermediate parent member of the group if—

(a)it is not a permanent establishment, investment entity, a partially-owned parent member or the ultimate parent, and

(b)it has—F2

(i)a direct or indirect ownership interest in another member of the group, orF2

(ii)a permanent establishment.F2

Notes

  1. F1

    S. 237(1)(b) 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. 3(2), 53(5)-(13)

  2. F2

    S. 237(2)(b) 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. 3(3), 53(5)-(13)

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