Part 3Multinational top-up tax
Chapter 1Introduction and charge
121Introduction to multinational top-up tax
1
The purpose of this Part is to implement the provisions of the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules).
2
3
The tax is to be known as “multinational top-up tax”.
4
Sections 122 to 124 set out the charge to multinational top-up tax and describe how it is to be calculated.
5
a
sets out the meaning of “multinational group”;
b
describes who the members of such a group are;
c
identifies the ultimate parent of such a group;
d
e
sets out how to determine which members of a multinational group (“responsible members”) are responsible for paying the tax and which members they are responsible for.