Schedules

Schedule 12U.K.Pillar Two

Part 2U.K.Multinational top-up tax

Blended CFC regimesU.K.

19(1)Section 180 (blended CFC regimes) is amended as follows.

(2)In subsection (5)(a), after “C” insert “in relation to the CFC entity”.

(3)In subsection (7)—

(a)after “C” insert “in relation to a CFC entity in which C has an ownership interest”, and

(b)for “F” substitute “the entity”.

(4)In subsection (8)(b) for sub-paragraph (ii) substitute—

(ii)the result of Step 2 in section 132(1) for those entities were the aggregate of their profits (and losses) before tax as shown in their financial accounts,

(iia)the combined covered tax balance for those entities were the aggregate of the taxes shown in their financial accounts,.