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Schedules

Schedule 12U.K.Pillar Two

Part 2U.K.Multinational top-up tax

Location of entitiesU.K.

32(1)In section 239(6)—

(a)in paragraph (c), omit “(3) or”, and

(b)in the words after paragraph (d), for “and 126” substitute “, 128 and 129”.

(2)In section 240 (location of flow-through entities), for subsection (1) substitute—

(1)Where a flow-through entity would be a responsible member of a multinational group if the entity were located in the territory in which it is created, it is located in that territory.