Finance (No. 2) Act 2023 (c. 30)

Part 3 U.K. Multinational top-up tax

Chapter 10 U.K. Definitions etc

Meaning of “entity” etc U.K.

237 Intermediate and partially-owned parent members U.K.

(1) A member of a multinational group is a partially-owned parent member of that group if—

(a) it is not a permanent establishment, investment entity or the ultimate parent,

(b) it has (directly or indirectly) an ownership interest in another member of the group, and

(c) more than 20% of the ownership interests that represent an entitlement to a share of the profits of the member are held by persons that are not members of the group.

(2) A member of a multinational group is an intermediate parent member of the group if—

(a) it is not a permanent establishment, investment entity, a partially-owned parent member or the ultimate parent, and

(b) it has (directly or indirectly) an ownership interest in another member of the group.