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Contents

Legislation
Finance (No. 2) Act 2023

Crossheading Miscellaneous

  • Section 252 Application to sovereign wealth funds
  • Section 253 Disqualified and qualified refundable imputation taxes
  • Section 254 Use of currency
  • Section 255 Pillar Two rules
  • Section 256 Qualifying domestic top-up tax
  • Section 256A Qualifying domestic top-up tax treated as not accruing where contested etc
  • Section 257 Qualifying undertaxed profits tax
  • Section 258 Meaning of “connected”
  • Section 259 Other definitions
  1. Miscellaneous
  2. Use of currency

Section 254 | Use of currency F1

From legislation.gov.uk

(1)Calculations under this Part in relation to a multinational group, or any member of such a group, are to be carried out in the currency of the consolidated financial statements of the ultimate parent (“the CFS currency”).

(2)Where it is necessary to convert an amount into the CFS currency, that conversion is to be made in accordance with the authorised accounting standard—

(a)that was used in preparing the consolidated financial statements of the ultimate parent, or

(b)where no such statements were prepared, that is used as the basis for the statements that would have been prepared.

(3)For the purpose of comparing an amount to a figure expressed in this Part in euros, the amount is to be converted to euros for that purpose (from the CFS currency) by reference to the average exchange rate for the month of December that preceded the beginning of the accounting period to which the amount relates.

(4)Where the European Central Bank publishes exchange rates for the CFS currency, use those rates for the purposes of the conversion under subsection (3) and any conversion under subsection (3) of section 123 (amount charged by reference to top-up amounts).F2

(5)Otherwise—

(a)where the Bank of England publishes exchange rates for the CFS currency, use those rates for the purposes of that conversion, or

(b)where the Bank of England does not publish exchange rates for that currency, use such a rate as appears, on a just and reasonable basis, to reflect the average exchange rate for the period in question.

Notes

  1. F1

    S. 254 substituted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 33(1)

  2. F2

    Words in s. 254(4) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 4(3), 10

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