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Legislation
Finance (No. 2) Act 2023

Chapter 3 Application of multinational top-up tax provisions

  • Section 272 Determining top-up amounts of entity that is a member of a group
  • Section 272A Treatment of covered bond vehicles
  • Section 273 Determining top-up amounts of entity that is not a member of a group
  • Section 273A References to Pillar Two rules
  • Section 273B Effect of becoming subject to Pillar Two rules
  • Section 273C Dividends from protected cell companies
  • Section 274 Application of section 262
  • Section 275 Application of Schedule 14
  • Section 276 Application of transitional provision
  • Section 277 Index of defined expressions
  • Section 278 Domestic top-up tax to apply from 31 December 2023
  1. Chapter 3 · Application of multinational top-up tax provisions
  2. Treatment of covered bond vehicles

Section 272A | Treatment of covered bond vehicles F1

From legislation.gov.uk

(1)This section applies where—F1

(a)a covered bond vehicle that is a member of a group would, ignoring this section, have a top-up amount or an additional top-up amount for an accounting period, andF1

(b)at least one of the other members of the group in that period—F1

(i)is located in the United Kingdom, andF1

(ii)is not a covered bond vehicle.F1

(2)For domestic purposes, section 193 (calculation of top-up amounts) has effect for the purpose of determining the top-up amounts (and additional top-up amounts) of—F1

(a)the covered bond vehicle, andF1

(b)the other members of the group that are located in the United Kingdom,F1

as if the adjusted profits of the covered bond vehicle were nil.

(3)But subsection (4) applies if none of the members of the group that are located in the United Kingdom, and are not covered bond vehicles, have made a profit for that period (and accordingly will not, ignoring that subsection, have top-up amounts).F1

(4)Each of those members has a top-up amount equal to the amount given by dividing—F1

(a)the sum of the top-up amounts and additional top-up amounts that, ignoring subsection (2), each covered bond vehicle located in the United Kingdom would otherwise have, byF1

(b)the number of those members.F1

(5)For the purposes of this section “covered bond vehicle” has the meaning given by paragraph 53(7) of Schedule 19 to FA 2011.F1

Notes

  1. F1

    S. 272A inserted (22.2.2024 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. 42(3)

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