Part 3Transitional reporting election

13Transitional reporting election

1

HMRC may publish a notice that provides for alternative requirements for the information that must be contained in an information return in respect of members of a multinational group to which an election under sub-paragraph (3) applies.

2

Where—

a

HMRC have published a notice under paragraph (1) containing alternative requirements, and

b

an election under sub-paragraph (3) applies to members of a multinational group for an accounting period,

paragraph 10 of Schedule 14 applies to the filing member of the group for that period subject to the notice.

3

An election under this sub-paragraph—

a

is to be made in respect of all of the members of a multinational group in a territory,

b

is to be made by the filing member of the group,

c

may only have effect in relation to an accounting period that begins on or before 31 December 2028 and ends before 1 July 2030, and

d

may only be made if condition A, B or C is met.

4

Condition A is that none of the members in the territory have top-up amounts or additional top-up amounts for the accounting period to which the election is to apply.

5

Condition B is that—

a

there is only one responsible member responsible for all of the members in the territory for the accounting period to which the election is to apply, and

b

the sum of amounts attributed under Chapter 7 of Part 3 to that responsible member for that period in respect of those members’ top-up amounts and additional top-up amounts is equal to the sum of the members’ top-up amount and additional top-up amounts.

6

Condition C is that—

a

there is more than one responsible member responsible for the members of the group in the territory for the accounting period to which the election is to apply, and

b

each responsible member is responsible for every member of the group in the territory and has the same inclusion ratio for each member it is responsible for.

7

Paragraph 2 of Schedule 15 (annual elections) applies to an election under this paragraph.

k

paragraph 14 of Schedule 16;