Schedules

Schedule 12U.K.Pillar Two

Part 4U.K.Minor and technical changes

Chapter 10 of Part 3 (definitions etc)U.K.

56(1)In section 231(1) (meaning of entity)—

(a)after paragraph (a), insert “or”,

(b)omit paragraphs (b) and (c), and

(c)in paragraph (d)—

(i)omit “other”, and

(ii)after “the arrangement” insert “(such as a partnership or trust)”.

(2)In section 232(1)(a) (permanent establishments treated as entities), for “of the main entity” substitute “in which the main entity is located”.

(3)In section 235(1)(b) (pension funds and pension services entities), at the beginning insert “it is”.

(4)In section 244 (calculating percentage ownership interests of a class), in subsection (2)(a), after “by” insert “an individual or by”.

(5)In section 245 (calculating percentage ownership interests: excluded entities), in subsection (2), after “Where” insert “an individual or”.

(6)In section 246(1)(b)(ii) (calculating percentage direct and indirect ownership interests) for “E” substitute “F”.

(7)In section 248 (exclusion of indirect interests held through ultimate parent), after “entity” insert “or individual”.

(8)In section 249(2) (consolidated financial statements)—

(a)for “an” substitute “the”, and

(b)after “standard” insert “that is used as the basis for the statements that would have been prepared”.

(9)In section 252(3) (application to sovereign wealth funds), for “government” substitute “governmental”.

(10)In section 253 (refundable imputation taxes)—

(a)in subsection (1)(a)(i)—

(b)for “in respect of a dividend made by the member and is” substitute “as a result of a dividend made by the member,”, and

(c)in subsection (2)(b)—

(i)in sub-paragraph (v), for the words from “, a resident pension fund” to the end substitute “or a resident pension fund”,

(ii)omit the “or” after that sub-paragraph, and

(iii)after that sub-paragraph insert—

(va)a resident investment entity that is not a member of the group, or.

(11)In section 259 (other definitions), in subsection (1)—

(a)at the appropriate place insert—

  • deemed distribution” has the meaning given by section 215(4)(c);, and

(b)in the definition of “tax treaty”, for “agreement for” substitute “international agreement for, or provision of an international agreement concerned with,”.