Paragraph 35 Substance based income exclusion: permanent establishments and flow-through entities

In section 197 (eligible tangible asset amount), after subsection (9) insert—

“(10)

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 an eligible tangible asset amount of nil (subject to the application of section 198ZB).”