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Part 3U.K.Multinational top-up tax

Chapter 8U.K.Further adjustments

Additional top-up amounts on recalculationsU.K.

207Allocation of collective additional amounts under section 206 to membersU.K.

(1)Where the standard members of a multinational group in a territory have a collective additional amount under section 206 for an accounting period (“the current period”), that amount is to be allocated to those members as follows—

(2)Chapter 7 (allocation of top-up amounts to responsible members)—

(a)applies to an additional top-up amount allocated to a member of a multinational group under this section as it applies to a top-up amount of that member, and

(b)if the result of Step 2 in section 132(1) in relation to the standard members of the group for the current period is nil or less (those members between them have made a loss), has effect as if the adjusted profits of that member were the amount given by dividing the additional top-up amount by 15%.