{
  "url": "https://openlegislation.uk/finance-act-2024/schedule-12/paragraph-39",
  "json_url": "https://openlegislation.uk/finance-act-2024/schedule-12/paragraph-39.json",
  "legislation": "ukpga/2024/3",
  "legislation_title": "Finance Act 2024",
  "legislation_url": "https://openlegislation.uk/finance-act-2024",
  "path": "schedule/12/paragraph/39",
  "kind": "paragraph",
  "number": "39",
  "heading": "Transitional safe harbour",
  "text": "(1) Part 2 of Schedule 16 (transitional safe harbour) is amended as follows.\n(2) In paragraph 3, for sub-paragraph (1) substitute—\n“(1) The filing member of a multinational group may make a transitional safe harbour election for an accounting period in respect of a territory.\n(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.”\n(3) In paragraph 4—\n(a) in sub-paragraph (3)—\n(i) omit the “and” after paragraph (b), and\n(ii) after paragraph (c) insert\n“, and\n(d) qualified substance based income amount (see paragraph 9(2)).”, and\n(b) in sub-paragraph (5), in the words before paragraph (a), for “(c)” substitute “(d)”.\n(4) In paragraph 6(6), for “if” substitute “unless”.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2024/3/schedule/12/paragraph/39",
    "retrieved_at": "2026-10-29T08:48:28.960167+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}