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Part 4U.K.Domestic top-up tax

Chapter 1U.K.Introduction

265Introduction to domestic top-up taxU.K.

(1)The purpose of this Part is to make provision for a qualified domestic minimum top-up tax within the meaning of the Pillar Two rules.

(2)For that purpose, this Part makes provision for a tax payable in respect of qualifying entities (that will be located in the United Kingdom) whose rate of tax (as determined in accordance with this Part) is less than 15%.

(3)The tax is to be known as โ€œdomestic top-up taxโ€.

(4)This Part applies (with modifications) many of the provisions of Part 3 (multinational top-up tax) for the purposes ofโ€”

(a)determining liability to domestic top-up tax, and

(b)administering domestic top-up tax.

(5)Except where the contrary appears, expressions used in this Part and in Part 3 (multinational top-up tax) have the same meaning in this Part as they have in Part 3.