Part 3Multinational top-up tax

Chapter 2Qualifying multinational groups and their members

Qualifying multinational groups

131Whether de-merged groups meet the revenue threshold

1

Where a multinational group is the result of a qualifying de-merger (“a de-merged group”), section 129 has effect in relation to that group for its first accounting period that ends after the de-merger, and in the 3 accounting periods that follow it as if for subsection (2) there were substituted—

2

A de-merged group meets condition A if—

a

in its first accounting period that ends after the de-merger, if its members have revenue for that period that exceeds the threshold set out in section 129(4), and

b

in any of the second to fourth accounting periods ending after the de-merger, if its members have revenue that exceeds the threshold set out in that section in any two of the following periods—

i

that period;

ii

any of the accounting periods that precede that period and end after the de-merger.

2

In this sectionqualifying de-merger” means the separation of members of a multinational group that meets condition A in section 129(2) into two or more consolidated groups, such that those members cease to all be consolidated by the same ultimate parent.