Finance Act 2024

Schedules 14 to 17 U.K.

58 (1) In Schedule 14 (administration)—

(a) in paragraph 6 (registration), after sub-paragraph (1) insert—

“(1A) The reference to a multinational group in sub-paragraph (1) does not include a group exclusively comprised of excluded entities (who are only regarded as members of the group for certain purposes in accordance with section 127(2)).”

(b) in paragraph 34 (group payment notices)—

(i) in sub-paragraph (2), for “the time the liability to tax arose” substitute “any time in the accounting period to which the amount payable relates”,

(ii) after that sub-paragraph insert—

“(2A) The references to a member of a group in sub-paragraph (2) do not include a member of a group that is—

(a) a securitisation company (within the meaning given by section 267(4)),

(b) a covered bond vehicle (within the meaning given by section 272A(5)), or

(c) an investment entity.”,

(c) in paragraph 35(1), for “ring-fenced entity”, in the second place it occurs, substitute “member of a ring-fenced body sub-group that the entity is a member of”,

(d) in paragraph 36(3), for the words from “person” to the end substitute “recipient is not a person to whom the notice can be given (see paragraphs 34(2) and (2A) and 35(1)).”, and

(e) in paragraph 37—

(i) in sub-paragraph (4)(b), after “for” insert “income tax or”, and

(ii) in sub-paragraph (6), for “payer” substitute “payee”.

(2) In Schedule 15 (elections)—

(a) in paragraph 1(1), after paragraph (a) insert—

“(aa) section 141(7);”, and

(b) in paragraph 2(1)—

(i) after paragraph (e) insert—

“(ea) section 199;”, and

(ii) after paragraph (f) insert—

“(fa) section 216;”.

(3) In Schedule 16 (multinational top-up tax: transitional provision), in paragraph 10—

(a) the existing words become sub-paragraph (1),

(b) in the words before paragraph (a) of that sub-paragraph—

(i) for “section 226” substitute “section 227”, and

(ii) after “groups)” insert “, that Chapter has effect as if”,

(c) in paragraph (a) of that sub-paragraph, for “3(2)(c)” substitute “3(2)(b)”, and

(d) after that sub-paragraph insert—

“(2) For that purpose ignore section 227(1)(a) (reference to ultimate parent treated as reference to joint venture parent).

(3) Accordingly, the filing member of a multinational group may make a separate transitional safe harbour election in respect of joint venture members of a joint venture group in a territory.”

(4) In Schedule 17 (index of defined expressions), in the table—

(a) in the definition of “government entity”, for “government” substitute “governmental”,

(b) in the definition of “pensions services entity” for “pensions” substitute “pension”, and

(c) at the appropriate places insert—

“CFS currency

section 254(1)”;

“country-by-country report

section 251A”;

“covered bond vehicle

section 272A(5)”;

“domestic purposes (in Part 4)

section 272(1)”;

“domestic entity purposes (in Part 4)

section 273(1)”;

“securitisation company

section 267(4)”;

“tax equity partnership arrangement

section 176D(5)”;

“transitional safe harbour election

section 255(6)”.