Part 3Multinational top-up tax
Chapter 9Special provision for investment entities, joint venture groups and minority-owned members
Investment entities
225Attribution of top-up amounts and additional top-up amounts to responsible member
1
In this section “top-up amount” includes an additional top-up amount determined under section 224.
2
Section 200 applies to the attribution of a top-up amount of a member of a multinational group that is an investment entity (“the relevant member”) to a responsible member as it applies to a top-up amount of any other member of the group.
3
Section 201 applies for the purpose of determining the inclusion ratio of the responsible member, but—
a
i
the adjusted profits of the entity determined in that Step are to be further adjusted in accordance with section 223 (to the extent applicable);
b
subsection (4) of that section applies whether or not the relevant member is a flow-through entity (so that entities that are not members of the group are always ignored).