# Finance Act 2025, Paragraph 34: Substance based income exclusion: permanent establishments and flow-through entities

Extent: E+W+S+N.I.

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).”

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/4/paragraph/34 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-4/paragraph-34
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.