Part 3U.K.Multinational top-up tax

Chapter 2U.K.Qualifying multinational groups and their members

Multinational groupsU.K.

126Meaning of “multinational group” and “ultimate parent”U.K.

(1)References in this Part to a multinational group are to a consolidated group where at least one of the members of that group is not located in the same territory as the others.

(2)A “consolidated group” means the following entities (which are its members)—

(a)an entity (the “ultimate parent”)—

(i)in which no other entity has a controlling interest, and

(ii)which has a controlling interest in other entities, and

(b)the entities whose assets, liabilities, income, expenses and cash flows—

(i)are included in the consolidated financial statements of the ultimate parent, or

(ii)are not included in those statements only because of an exclusion on size or materiality grounds or on the grounds that the entity in question is held for sale.