Part 4Domestic top-up tax
Chapter 3Application of multinational top-up tax provisions
272AF1Treatment of covered bond vehicles
1
This section applies where—
a
a covered bond vehicle that is a member of a group would, ignoring this section, have a top-up amount or an additional top-up amount for an accounting period, and
b
at least one of the other members of the group in that period—
i
is located in the United Kingdom, and
ii
is not a covered bond vehicle.
2
For domestic purposes, section 193 (calculation of top-up amounts) has effect for the purpose of determining the top-up amounts (and additional top-up amounts) of—
a
the covered bond vehicle, and
b
the other members of the group that are located in the United Kingdom,
as if the adjusted profits of the covered bond vehicle were nil.
3
But subsection (4) applies if none of the members of the group that are located in the United Kingdom, and are not covered bond vehicles, have made a profit for that period (and accordingly will not, ignoring that subsection, have top-up amounts).
4
Each of those members has a top-up amount equal to the amount given by dividing—
a
the sum of the top-up amounts and additional top-up amounts that, ignoring subsection (2), each covered bond vehicle located in the United Kingdom would otherwise have, by
b
the number of those members.
5
For the purposes of this section “covered bond vehicle” has the meaning given by paragraph 53(7) of Schedule 19 to FA 2011.