Part 3Multinational top-up tax

Chapter 9Special provision for investment entities, joint venture groups and minority-owned members

Investment entities

221Substance based income exclusion for investment entity

(1)

The substance based income exclusion for an investment entity is to be determined by adding together—

(a)

the payroll carve-out amount of the entity, and

(b)

the tangible asset carve-out amount of the entity,

(2)

Section 195(4) applies to the determination of the payroll carve-out amount of the entity as it applies for members of the group that are not investment entities.

(3)

Section 195(5) applies to the determination of the tangible asset carve-out amount of the entity as it applies for members of the group that are not investment entities.

(4)

If the filing member for the group elects not to calculate the substance based income exclusion for the period in a self-assessment (see F1Schedule 14), the exclusion is nil.

(5)

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