Finance Act 2024

Charging permanent establishments of intermediate/partially-owned parent members U.K.

4 (1) Section 128 (responsible members) is amended as follows.

(2) In subsection (3), for paragraph (c) substitute—

“(c) at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.”

(3) In subsection (4), after “for” insert “—

(a) every permanent establishment for which it is the main entity, and

(b)”.

(4) In subsection (5), for paragraph (b) substitute—

“(b) at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.”

(5) In subsection (6), after “for” insert “—

(a) every permanent establishment for which it is the main entity, and

(b)”.

(6) In section 232, after subsection (3) insert—

“(3A) But an entity with a permanent establishment is not to be taken as having ownership interests in that permanent establishment.”