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Part 3U.K.Multinational top-up tax

Chapter 7U.K.Allocating top-up amounts to responsible members

200Top-up amounts multiplied by inclusion ratioU.K.

(1)The amount of a top-up amount of a member of a multinational group that is attributed to a responsible member (see section 128) is found by multiplying the top-up amount by the responsible member’s inclusion ratio for the member whose top-up amount it is.

(2)Where the responsible member’s (“the first responsible member”) interest in the member is through another responsible member, the first responsible member’s top-up amount is to be reduced (but not below nil) by the amount attributed under this section to that other responsible member.