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.