Part 1 General Transitional Measures
Finance (No 2) Act 2023 (2023 c 30) | Legislation

SCHEDULE 16 Multinational Top-up Tax: Transitional Provision

Section 260

Part 1 General Transitional Measures

Transitional relief for substance-based income exclusion

1

(1)     Section 195(4) (payroll carve-out amount) has effect for an accounting period that commences in a year listed in following table as if for “5%†there were substituted the specified percentage for that year—

YearSpecified percentage
202310%
20249.8%
20259.6%
20269.4%
20279.2%
20289.0%
20298.2%
20307.4%
20316.6%
20325.8%

(2)     Section 195(5) (tangible asset carve-out amount) has effect for an accounting period that commences in a year listed in following table as if for “5%†there were substituted the specified percentage for that year—

YearSpecified percentage
20238%
20247.8%
20257.6%
20267.4%
20277.2%
20287.0%
20296.6%
20306.2%
20315.8%
20325.4%

Intra-group transfers before entry into regime

2

(1)     Sub-paragraph (3) applies where—

(a)     assets are transferred from one member of a multinational group to another member of that group,

[(b)

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