Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

24Substance based income exclusion: dual use assets

In section 197, after subsection (7) insert—

7A

Where part of an asset comprising property is held by a member of a multinational group for lease, but another part of that property is retained for use by the member—

a

the parts are to be treated as separate assets for the purposes of this section and section 197A, and

b

the carrying value of the asset is to be allocated between the separate parts on a just and reasonable basis.