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Paragraph 34 Substance based income exclusion: permanent establishments and flow-through entities

United Kingdom

In section 196 (eligible payroll costs), after subsection (6) insert—

“(7)

A member of a multinational group that is a flow-through entity that is a responsible member of the group but which is not the ultimate parent is to be regarded as having nil eligible payroll costs (subject to the application of section 198ZA).”