Part 3Multinational top-up tax
Chapter 1Introduction and charge
124How to calculate top-up amounts and attribute them
1
Generally, a member of a multinational group in a territory will have a top-up amount for an accounting period if—
a
the effective tax rate of the members of the group in that territory for that period is less than 15%, and
b
that member has profits for that period.
2
3
4
a
which taxes (referred to in this Part as “covered taxes”) are to be considered in determining the effective tax rate of those members, and
b
how to determine the amount of covered taxes allocated to those members.
5
6
7
a
additional top-up amounts, and
b
further adjustments that may need to be made (including provision about adjustments for restructuring of multinational groups).
8
9
Chapter 10 of this Part contains definitions and other provisions relevant to the calculations and other determinations to be made for the purposes of multinational top-up tax and Chapter 11 contains general provision.