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Paragraph 41 Joint ventures

United Kingdom

(1)

Section 266 (qualifying entities) is amended as follows.

(2)

In subsection (1), after “An entity” insert “which is not a member of a joint venture group”.

(3)

After subsection (1) insert—

“(1A)

A member of a joint venture group is a qualifying entity for an accounting period if—

(a)

the member is not a DTT excluded entity,

(b)

the member meets condition A for that period, and

(c)

the revenue condition is met in relation to the group for that period.

(1B)

For the purposes of subsection (1A) the “revenue condition” is met in relation to a joint venture group for an accounting period if—

(a)

a single entity which directly or indirectly holds at least 50% of the ownership interests in the joint venture parent meets Condition A and Condition B for that period, or

(b)

the members of a group (the “relevant group”) whose ultimate parent directly or indirectly holds at least 50% of the ownership interests in the joint venture parent meet Condition C for that period and—

(i)

all of those members are located in the United Kingdom, or

(ii)

the relevant group is a multinational group (see section 126 in Part 3), and at least one of the members is located in a Pillar Two territory.”