Schedules

Schedule 12Pillar Two

Part 2Multinational top-up tax

4Charging permanent establishments of intermediate/partially-owned parent members

1

Section 128 (responsible members) is amended as follows.

2

In subsection (3), for paragraph (c) substitute—

c

at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.

3

In subsection (4), after “for” insert

—

a

every permanent establishment for which it is the main entity, and

b

4

In subsection (5), for paragraph (b) substitute—

b

at least one member of the group in which it has an ownership interest, or a permanent establishment for which it is the main entity, has a top-up amount or an additional top-up amount.

5

In subsection (6), after “for” insert

—

a

every permanent establishment for which it is the main entity, and

b

6

In section 232, after subsection (3) insert—

3A

But an entity with a permanent establishment is not to be taken as having ownership interests in that permanent establishment.