Part 2 Multinational top-up tax

United Kingdom

1. 2Partnerships
2. 3Qualifying non-profit subsidiaries
3. 4Charging permanent establishments of intermediate/partially-owned parent members
4. 5De-merged groups
5. 6Adjustment for changes in accounting policies and prior period errors
6. 7Pension expense
7. 8Tax credits
8. 9Adjustments for companies in distress
9. 10Adjustments where life assurance business carried on
10. 11Exclusion of certain insurance reserve movement expense
11. 12Permanent establishment income and expense attribution
12. 13Election to spread certain capital gains
13. 14Transparent entities etc
14. 15Covered taxes
15. 16Tax equity partnerships
16. 17Reallocation of tax expense
17. 18Controlled foreign company tax regimes
18. 19Blended CFC regimes
19. 20Qualifying foreign tax credits (substitute loss carry forward assets)
20. 21Substance based income exclusion: inter-jurisdictional employees and assets
21. 22Substance based income exclusion: inclusion of payroll costs and assets voluntary
22. 23Substance based income exclusion: impairment losses
23. 24Substance based income exclusion: dual use assets
24. 25Substance based income exclusion: leases
25. 26Substance based income exclusion: power to make further provision
26. 27Transfer of assets or liabilities to a member of a multinational group
27. 28Investment entity tax transparency election
28. 29Meaning of country-by-country report
29. 30Joint ventures
30. 31Insurance investment entities
31. 32Location of entities
32. 33Currency
33. 34Application of Pillar Two rules to members of a group
34. 35Qualifying domestic top-up tax not treated as accruing
35. 36Consistency with Pillar Two rules
36. 37Overpaid tax
37. 38Intragroup transfers before entry into regime
38. 39Transitional safe harbour
39. 40Transitional reporting election
40. 41Qualifying domestic top-up tax safe harbour