[Part 1 Qualifying Domestic Top-up Tax Safe Harbour]
Finance (No 2) Act 2023 (2023 c 30) | Legislation

[SCHEDULE 16A Multinational Top-up Tax: Safe Harbours]

[Section 260]

[Part 1 Qualifying Domestic Top-up Tax Safe Harbour]

[Chapter 1
Qualifying Domestic Top-up Tax Safe Harbour Election

Election for qualifying domestic top-up tax safe harbour

1

(1)     The filing member of a multinational group may make a qualifying domestic top-up tax safe harbour election for an accounting period in respect of a territory.

(2)     The effect of the election is that all of the standard members of the group located in the territory are to be treated as not having top-up amounts or additional top-up amounts for the purpose of determining the liability of any member of the group to multinational top-up tax.

(3)     An election may only be made for an accounting period if—

(a)     a qualifying domestic top-up tax applies in that territory for that period,

(b)     that tax is accredited for the purposes of the election (see paragraph 2), and

(c)     none of the disqualifying conditions in paragraph 3 apply for that period.

(4)     Paragraph 2 of Schedule 15 (annual elections) applies to an election under this paragraph.

Accredited qualifying domestic top-up tax

2

A qualifying domestic top-up tax is accredited for the

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