determining liability to domestic top-up tax, and

administering domestic top-up tax.

if it is not a member of a group, it meets condition B for that period, or

if it is a member of a group, it meets condition C for that period.

references to “multinational group” were to “group”,

in section 131(2), for “condition A in section 129(2)” there were substituted “condition C in section 266(5)”

financial statements of the entity prepared in accordance with acceptable accounting standards, or

it falls within subsection (3) of section 127 in Part 3 (excluded entities),

it is a member of a multinational group and falls within subsection (4) of that section, or

it is a member of a group that is not a multinational group, but would fall within that subsection if that group were a multinational group.

it is not a member of a group, or

it is a member of group that is comprised only of members located in the United Kingdom.

is not to be regarded as a qualifying entity, but

top-up amounts of that entity are to be determined under sections 220 to 224 (see also section 272(8)(e) which has the effect of attributing those amounts to standard members of the group that are qualifying entities and are located in the same territory as the investment entity).

determining the top-up amounts of that entity under those sections,

applying Condition C in section 266 in relation to other members of the group (revenue threshold for group), and

subsections (8)(e) (9), (10) and (11) of section 272.

the person is a qualifying entity for that period and is a body corporate or a partnership F12..., or

the entity has profits that are chargeable to income tax or corporation tax, and

the person is resident in the United Kingdom for the purposes of that tax.

those profits,

which taxes (referred to as “covered taxes”) are to be considered in the determining effective tax rates,

top-up amounts, and

additional top-up amounts.

no member of the group other than the F16elected member is required to pay any amount by way of domestic top-up tax, and

the F16elected member must pay any amount by way of domestic top-up tax any other member of the group would have been required to pay if the election had not been made.

in section 194, subsections (2) to (7);

in section 203, subsections (3) to (7);

in section 206, subsections (4) to (8).

section 173(1)(b) and sections 189 to 192 (eligible distribution tax systems);

section 225 (attribution of top-up amounts of investment entities).

an election is made under Part 3 in relation to a member of a multinational group (whether or not a qualifying entity) for the purposes of multinational top-up tax, and

if the election had effect for domestic purposes, it would affect the calculation of top-up amounts or additional top-up amounts,

made in respect of a group in connection with a tax equivalent to multinational top-up tax in another Pillar Two territory;

section 134 (underlying profits as determined for statements of ultimate parent) has effect as if, after subsection (3), there were inserted—

section 176 (amounts to be reflected in covered tax balance) has effect as if, for subsection (2)(i) (amounts allocated from another member of the group), there were substituted—

section 179 (controlled foreign companies) has effect as if subsection (2) (restriction on allocation to CFC) were omitted;

in section 182(2)(e), after “credits”, in the first place it occurs, there were inserted “other than qualifying refundable tax credits”;

section 193 (calculation of top-up amounts) has effect F18in relation to a qualifying entity that is a standard member of a group as if the total top-up amount referred to in that section included any top-up amounts or additional top-up amounts of F19qualifying investment entities determined under sections 220 to 224.

a member of the same group as the qualifying entity, and

located in United Kingdom.

the total top-up amount referred to in section 193 for that period is greater than nil as a result of the modification of that section set out in subsection (8)(e), and

none of those members have made a profit for that period (and accordingly will not, ignoring subsection (11), have top-up amounts).

a covered bond vehicle that is a member of a group would, ignoring this section, have a top-up amount or an additional top-up amount for an accounting period, and

the covered bond vehicle, and

the other members of the group that are located in the United Kingdom,

the sum of the top-up amounts and additional top-up amounts that, ignoring subsection (2), each covered bond vehicle located in the United Kingdom would otherwise have, by

the number of those members.

references to “member of a multinational group” (however framed and including references to multiple members) were to “qualifying entity”;

any reference (however framed) to the consolidated financial statements of the ultimate parent were to the qualifying financial statements of the entity;

in section 182(2)(e), after “credits”, in the first place it occurs, there were inserted “other than qualifying refundable tax credits”;

in section 194 (total top-up amount), subsections (2) to (7) were omitted;

in section 203 (additional top-up amounts: covered taxes less than expected), subsections (3) to (7) were omitted;

in section 206 (additional top-up amounts: recalculations), subsections (4) to (8) were omitted.

in section 134 (underlying profits as determined for statements of ultimate parent), subsections (2) to (9);

section 135 (permanent establishments);

section 139 (consolidation adjustments);

section 140 (purchase accounting adjustments);

in section 141 (general exclusion of dividends), F25subsection (3)(c);

section 149 (arm’s length requirement);

section 150 (transactions between group members);

section 154 (exclusion of qualifying intra-group financing arrangement expenses);

sections 159 and 160 (adjustments applicable to permanent establishments);

in section 163 (election to spread capital gains), subsection (3);

section 164 (election to exclude intra-group transactions);

section 167 (underlying profits of member of group seen as transparent);

in section 168 (underlying profits of flow-through entities), subsection (8);

section 169 (non-tax resident entities to be treated as flow-through entities);

section 170 (adjustments for ultimate parent that is flow-through entity);

section 172 (ultimate parent subject to deductible dividend regime);

in section 173 (covered taxes), subsection (1)(b);

section 177 (allocation of covered taxes: permanent establishments);

section 178 (reallocation of tax expense);

sections 179 and 180 (controlled foreign company tax regimes);

section 181 (distributions from other group members);

section 183 (qualifying foreign tax credits);

sections 189 to 192 (deemed distribution tax election);

sections 208 to 212 (restructuring of groups);

sections 213 to 215 (elections in relation to investment entities);

in section 216 (election where assets and liabilities adjusted to fair value), subsection (6);

sections 226 to 229 (joint venture groups, minority owned members and multi-parent groups).

section 185;

section 187;

sub-paragraph (4) of paragraph 2 of Schedule 16 (but see also section 276(c)(iii) which omits that paragraph in the case of a qualifying entity that is not a member of a group).

the entity has a recaptured deferred tax liability arising as a result of section 184 (recaptured deferred tax liabilities),

the initial period, in relation to that liability, is a pre-Pillar Two period, and

the first accounting period in which the Pillar Two rules apply to the entity is earlier than the sixth accounting period after the initial period,

the election ceases to have effect for the first accounting period in which the Pillar Two rules apply, and

subsection (2)(b) of section 187 does not apply to prevent the making of an election under section 187 that applies to the entity and that has effect for that period, but

no remaining amount of special loss deferred tax assets that arose in a pre-Pillar Two period may be used in that first accounting period or any subsequent accounting period.

a deferred tax asset arises to the entity in a pre-Pillar Two period,

the asset is reflected in a collective additional amount for the purposes of domestic top-up tax.

an election has been made under section 205 (election to carry forward) in relation to the collective additional amount,

the subtraction required by subsection (2)(a) of that section has not occurred in a pre-Pillar Two period,

a qualifying entity that is not a member of a group, or

a member of a group that has no members located outside of the United Kingdom.