Finance (No. 2) Act 2023
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Change 1
189 Deemed distribution tax election
(1) The filing member of a multinational group may make an election that section 190 (deemed distribution tax) applies to all of the standard members of the group in a particular territory for an accounting period. (2) An election under subsection (1) may only be made in relation to a territory if that territory has an eligible distribution tax system. (3) In this Part “eligible distribution tax system” means a system of tax on company profits that— (a) is generally only payable when a company distributes, or is deemed to distribute, those profits to its members, or when it incurs certain non-business expenses, (b) is charged at a rate of at least 15%, and (c) was in force on or before 1 July 2021. (4) Paragraph 2 of Schedule 15 (annual elections) applies to an election under this section.
189 Deemed distribution tax election
(1) The filing member of a multinational group may make an election that section 190 (deemed distribution tax) applies to all of the standard members of the group in a particular territory for an accounting period. (2) An election under subsection (1) may only be made in relation to a territory if that territory has an eligible distribution tax system. (3) In this Part “eligible distribution tax system” means a system of tax on company profits that— (a) is generally only payable when a company distributes, or is deemed to distribute, those profits to its members, or when it incurs certain non-business expenses, (b) is charged at a rate of at least 15%, and (c) was in force on or before 1 July 2021. (4) Paragraph 2 of Schedule 15 (annual elections) applies to an election under this section.
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