Part 3Multinational top-up tax
Chapter 1Introduction and charge
122Chargeable persons
1
A person is chargeable to multinational top-up tax for an accounting period of a multinational group if the group is a qualifying multinational group in that period and—
a
the person—
i
is a responsible member of the multinational group at any time in that period,
ii
is a body corporate or a partnership F1..., and
iii
is located in the United Kingdom, or
b
the person is chargeable to tax in respect of an entity that is a responsible member of the multinational group at any time in that period.
2
A person is chargeable to tax in respect of a responsible member of a multinational group if—
a
the profits of the responsible member would, on the relevant assumptions, be the profits of the person for the purposes of income tax or corporation tax,
b
the responsible member is located in the United Kingdom, and
3
The relevant assumptions are—
a
that the responsible member has profits that are chargeable to income tax or corporation tax, and
b
that the person is resident in the United Kingdom for the purposes of that tax.
F34
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F35
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F36
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7
Where more than one person is chargeable to tax in relation to the same responsible member of a qualifying multinational group as a result of the application of subsection (2), each of those persons is jointly and severally liable to multinational top-up tax.