{
  "url": "https://openlegislation.uk/finance-act-2025/schedule-4/paragraph-25",
  "json_url": "https://openlegislation.uk/finance-act-2025/schedule-4/paragraph-25.json",
  "legislation": "ukpga/2025/8",
  "legislation_title": "Finance Act 2025",
  "legislation_url": "https://openlegislation.uk/finance-act-2025",
  "path": "schedule/4/paragraph/25",
  "kind": "paragraph",
  "number": "25",
  "heading": "Blended CFC regimes",
  "text": "(1) Section 180 (blended CFC regimes) is amended as follows.\n(2) In subsection (8)—\n(a) in paragraph (a), for “the effective tax rate of” substitute “a single effective tax rate of all”;\n(b) after paragraph (a) insert—\n“(aa) where—\n(i) the CFC entity is a member of the multinational group,\n(ii) different effective tax rates are calculated for the period for different subsets of (one or more) members of the multinational group located in the territory where the CFC entity is located (“local blending subsets”), and\n(iii) the CFC entity is a member of a local blending subset,\nthe effective tax rate of the local blending subset of which the CFC entity is a member, calculated on the assumptions set out in paragraph (a)(i) and (ii) (“the relevant assumptions”);\n(ab) where—\n(i) the CFC entity is not a member of the multinational group, or is a member of the multinational group but not a member of any local blending subset, and\n(ii) different effective tax rates are calculated for the period for different local blending subsets,\nthe effective tax rate, calculated on the relevant assumptions, of the local blending subset whose members have collectively the highest attributable income of C in relation to the CFC entity (as mentioned in subsection (5)(a));”;\n(c) in paragraph (b)—\n(i) for “where it is not located in such a territory,” substitute “where no applicable effective tax rate can be determined under paragraphs (a) to (ab)”, and\n(ii) at the end insert—\n“But this is subject to section 180A.”\n(3) After section 180 insert—\n“Section 180: further provision\n180A (1) Where the filing member of the multinational group mentioned in section 180(8)(a) has made a transitional safe harbour election under paragraph 3 of Schedule 16 for the relevant period in respect of the territory mentioned in section 180(8)(a), for the purposes of that section the effective tax rate of the members of the group in respect of which the election applies is to be taken to be the simplified effective tax rate of the standard members of the multinational group (as defined in paragraph 8 of Schedule 16)).\n(2) Where the filing member of the multinational group mentioned in section 180(8)(a) has made a transitional safe harbour election under paragraph 10 of Schedule 16 (application in the case of joint venture group) for the relevant period in respect of the territory mentioned in section 180(8)(a), for the purposes of that section the effective tax rate of the members of the group in respect of which the election applies is to be taken to be the simplified effective tax rate of the standard members of that multinational group (as defined in paragraph 8 of Schedule 16).\n(3) Subsection (4) has effect where the filing member of a particular multinational group mentioned in section 180(8)(a) has made one or more separate elections under any of paragraphs 1, 4, 5 and 6 of Schedule 16A for the relevant period in respect of the territory mentioned in section 180(8)(a).\n(4) For the purposes of section 180, the effective tax rate of any member or set of members to which a particular election mentioned in subsection (4) relates is to be the rate (expressed as a percentage) given by dividing—\n(a) the aggregate tax expense of that member or set of members used to determine the effective tax rate for the purposes of the qualifying domestic top-up tax applying in the territory for the accounting period, together with any amounts of qualifying domestic top-up tax paid of that member or set of members, by\n(b) the income of that member or set of members determined for the purposes of the qualifying domestic top-up tax.\n(5) In this section “relevant period” is to be interpreted in accordance with section 180(2)(a).”",
  "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/2025/8/schedule/4/paragraph/25",
    "retrieved_at": "2026-10-29T08:47:01.939707+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."
}