229 Multi-parent groups

Application to multi-parent groups

229  Multi-parent groups

(1)     Where two or more consolidated groups form part of a multi-parent group—

(a)     those groups (“the constituent groups”) are to be treated as a single multinational group (and accordingly multinational top-up tax will be charged in relation to that single group), and

(b)     the group's members include (as well as the members who are members as a result of section 126) entities who would not be a member of any of the constituent groups but in which a controlling interest is held by one or more members of the constituent groups,

(2)     This Part has effect, in its application to a multi-parent group, as if—

(a)     references (however framed) to the consolidated financial statements of the ultimate parent were to the multi-parent consolidated financial statements,

(b)     references to the ultimate parent were to all of the ultimate parents of the constituent groups, other than the reference in section 128(3)(b) (responsible members).

(3)     Where ownership interests in an intermediate parent member of a multi-parent group are held by more than one of the ultimate parents of the multi-parent group, [section 128(3)] has effect as if for paragraph (b) there were substituted—

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