213 Investment entity tax transparency election
Finance (No 2) Act 2023 (2023 c 30) | Legislation

Elections in Relation to Investment Entities

213  Investment entity tax transparency election

(1)     The filing member of a multinational group may make an investment entity tax transparency election in relation to a member of the group that is an investment entity (“M”) and a member of the group with ownership interests in that entity (“O”).

(2)     For the purposes of determining whether O has ownership interests in M, only interests that give rise to a share of profits are to be taken into account.

(3)     An investment entity tax transparency election is an election that, for the purposes of sections 168 (underlying profits of transparent entities) and 178 (covered taxes of transparent entities)—

(a)     M is to be treated as a flow-through entity,

(b)     M is to be treated as regarded as tax transparent in the territory of O, and

(c)

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