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Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

Substance based income exclusion: dual use assets

24In 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.