Paragraph 39 Transitional safe harbour

United Kingdom

(1)

Part 2 of Schedule 16 (transitional safe harbour) is amended as follows.

(2)

In paragraph 3, for sub-paragraph (1) substitute—

“(1)

The filing member of a multinational group may make a transitional safe harbour election for an accounting period in respect of a territory.

(1A)

The effect of the election is that all of the standard members of the group located in the territory are to be treated as not having top-up amounts or additional top-up amounts for the purpose of determining the liability of any member of the group to multinational top-up tax.”

(3)

In paragraph 4—

(a)

in sub-paragraph (3)—

(i)

omit the “and” after paragraph (b), and

(ii)

after paragraph (c) insert

“, and

(d)

qualified substance based income amount (see paragraph 9(2)).”, and

(b)

in sub-paragraph (5), in the words before paragraph (a), for “(c)” substitute “(d)”.

(4)

In paragraph 6(6), for “if” substitute “unless”.