Propose a change

Finance (No. 2) Act 2023

Write the words of this act the way you think they should read. Solon shows your change as a redline against the published text and pins it to that exact text, so it can never be applied to wording you did not see.

Change 1

What to do with it
As published

128 Responsible members

(1) The ultimate parent of a multinational group is a responsible member of that group if it is subject to Pillar Two IIR tax. (2) An ultimate parent that is a responsible member of a multinational group is responsible for all of the members of the group that are not located in the territory the ultimate parent is located in. (3) An intermediate parent member of a multinational group (see section 237(2)) that is located in a Pillar Two territory is a responsible member of that group if it is subject to Pillar Two IIR tax and— (a) no intermediate parent member of that group that is subject to Pillar Two IIR tax has a controlling interest in it, (b) the ultimate parent is not subject to Pillar Two IIR tax, and (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. (4) Such an intermediate parent member is responsible for — (a) every permanent establishment for which it is the main entity, ... (b) all of the members of the group it has an ownership interest in that are not located in the territory it is located in , and (c) every permanent establishment of a member of the group it has an ownership interest in other than a permanent establishment located in the territory it is located in. (5) A partially-owned parent member of a multinational group (see section 237(1)) that is located in a Pillar Two territory is a responsible member if it is subject to Pillar Two IIR tax and— (a) it is not wholly owned by another partially-owned parent member of that group that is subject to Pillar Two IIR tax, and (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. (6) Such a partially owned parent member is responsible for — (a) every permanent establishment for which it is the main entity, ... (b) all of the members of the group it has an ownership interest in that are not located in the same territory it is located in , and (c) every permanent establishment of a member of the group it has an ownership interest in other than a permanent establishment located in the territory it is located in. (7) For the purposes of this Part an entity is subject to Pillar Two IIR tax for an accounting period if— (a) the period commences on or after 31 December 2023 and the entity is located in the United Kingdom and is not an excluded entity, or (b) the entity— (i) is located in another Pillar Two territory in which a tax equivalent to the IIR provisions of multinational top-up tax is in force for the period, and (ii) is not excluded from the application of that tax as a result of provision equivalent to section 127. (7A) If for an accounting period— (a) the application in relation to an entity located in a territory of a tax equivalent to the IIR provisions of multinational top-up tax depends on the making by any person of an election or claim, and (b) the tax does not apply in relation to the entity because such an election or claim is or is not made, subsection (7)(b)(i) has effect in relation to the entity as though the tax were not in force in the territory for the period. (8) In this section the “IIR provisions of multinational top-up tax” means the provisions of this Part relating to the charging of top-up amounts and additional top-up amounts (but not untaxed amounts).

Your change, as a redline

128 Responsible members

(1) The ultimate parent of a multinational group is a responsible member of that group if it is subject to Pillar Two IIR tax. (2) An ultimate parent that is a responsible member of a multinational group is responsible for all of the members of the group that are not located in the territory the ultimate parent is located in. (3) An intermediate parent member of a multinational group (see section 237(2)) that is located in a Pillar Two territory is a responsible member of that group if it is subject to Pillar Two IIR tax and— (a) no intermediate parent member of that group that is subject to Pillar Two IIR tax has a controlling interest in it, (b) the ultimate parent is not subject to Pillar Two IIR tax, and (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. (4) Such an intermediate parent member is responsible for — (a) every permanent establishment for which it is the main entity, ... (b) all of the members of the group it has an ownership interest in that are not located in the territory it is located in , and (c) every permanent establishment of a member of the group it has an ownership interest in other than a permanent establishment located in the territory it is located in. (5) A partially-owned parent member of a multinational group (see section 237(1)) that is located in a Pillar Two territory is a responsible member if it is subject to Pillar Two IIR tax and— (a) it is not wholly owned by another partially-owned parent member of that group that is subject to Pillar Two IIR tax, and (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. (6) Such a partially owned parent member is responsible for — (a) every permanent establishment for which it is the main entity, ... (b) all of the members of the group it has an ownership interest in that are not located in the same territory it is located in , and (c) every permanent establishment of a member of the group it has an ownership interest in other than a permanent establishment located in the territory it is located in. (7) For the purposes of this Part an entity is subject to Pillar Two IIR tax for an accounting period if— (a) the period commences on or after 31 December 2023 and the entity is located in the United Kingdom and is not an excluded entity, or (b) the entity— (i) is located in another Pillar Two territory in which a tax equivalent to the IIR provisions of multinational top-up tax is in force for the period, and (ii) is not excluded from the application of that tax as a result of provision equivalent to section 127. (7A) If for an accounting period— (a) the application in relation to an entity located in a territory of a tax equivalent to the IIR provisions of multinational top-up tax depends on the making by any person of an election or claim, and (b) the tax does not apply in relation to the entity because such an election or claim is or is not made, subsection (7)(b)(i) has effect in relation to the entity as though the tax were not in force in the territory for the period. (8) In this section the “IIR provisions of multinational top-up tax” means the provisions of this Part relating to the charging of top-up amounts and additional top-up amounts (but not untaxed amounts).

One line that says what changes, such as "Halve the dog tax".

Who it helps, what it costs, what it fixes. It is what persuades people to support it.

A proposal here is not law. Support on Solon is evidence that people want the change; the official route says what it takes to make it law.

Sign in to file your proposal. What you have written stays on this page.

Sign in to file it

Think it through

Ask what your change would do, who would gain and who would bear a cost, and where something like it is already law. The assistant reads your draft as it stands, cites the law and the studies it finds, and takes no side. What you file stays yours.

Questions to start with
Think it through
Legal information from the published text, not advice for your case. Check the sources. Find a law · What the register holds