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Part 3U.K.Multinational top-up tax

Chapter 10U.K.Definitions etc

MiscellaneousU.K.

252Application to sovereign wealth fundsU.K.

(1)A sovereign wealth fund that would, ignoring this subsection, be the ultimate parent of a multinational group is not to be regarded as the ultimate parent of that group and is to be ignored for the purposes of this Part.

(2)Accordingly, an entity (“A”) in which such a sovereign wealth fund has a controlling interest as a result of direct ownership interests is to be regarded as the ultimate parent of a consolidated group consisting of—

(a)itself, and

(b)the entities that A has a controlling interest in.

(3)For the purposes of this sectionsovereign wealth fund” means an entity which is a government entity for the purposes of this Part as a result of meeting the condition in section 234(1)(b)(ii).