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Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

Currency

33(1)For section 254 (use of currency) substitute—

254Use of currency

(1)Calculations under this Part in relation to a multinational group, or any member of such a group, are to be carried out in the currency of the consolidated financial statements of the ultimate parent (“the CFS currency”).

(2)Where it is necessary to convert an amount into the CFS currency, that conversion is to be made in accordance with the authorised accounting standard—

(a)that was used in preparing the consolidated financial statements of the ultimate parent, or

(b)where no such statements were prepared, that is used as the basis for the statements that would have been prepared.

(3)For the purpose of comparing an amount to a figure expressed in this Part in euros, the amount is to be converted to euros for that purpose (from the CFS currency) by reference to the average exchange rate for the month of December that preceded the beginning of the accounting period to which the amount relates.

(4)Where the European Central Bank publishes exchange rates for the CFS currency, use those rates for the purposes of the conversion under subsection (3) and any conversion under step 4 in section 123 (amount charged by reference to top-up amounts).

(5)Otherwise—

(a)where the Bank of England publishes exchange rates for the CFS currency, use those rates for the purposes of that conversion, or

(b)where the Bank of England does not publish exchange rates for that currency, use such a rate as appears, on a just and reasonable basis, to reflect the average exchange rate for the period in question.

(2)In section 123 (amount charged by reference to “top-up amounts”), for Step 4 substitute—