Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

Insurance investment entities

31(1)Section 236 (investment funds and investment entities) is amended as follows.

(2)In subsection (2)—

(a)omit paragraph (b),

(b)for paragraph (c) substitute—

(c)the income or gains the entity is designed to generate are intended to offset liabilities under insurance or annuity contracts;, and

(c)for paragraph (e) substitute—

(e)regulated entities hold 100% of the ownership interests in it (see section 244 for how to calculate this).

(3)After that subsection insert—

(2A)An entity is a regulated entity if—

(a)the entity is subject to a regulatory regime in the territory in which it is established or managed, and

(b)that regime is specific to persons engaged in the business of entering into insurance or annuity contracts or of performing activities ancillary to such business.