# Finance Act 2025, Paragraph 45: De minimis rule

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

(1) In section 199 (election to treat total top-up amount as nil)—
(a) in subsection (1)—
(i) for “total top-up amount” substitute “top-up amounts of the relevant members”, and
(ii) for “is” substitute “are”;
(b) in subsections (2)(a), (3), (4), (6)(a) and (6)(b), for “standard” substitute “relevant”;
(c) after subsection (2) insert—
“(2A) In this section, a member of a multinational group is a “relevant” member if it is—
(a) a standard member of the group, or
(b) a minority owned member of the group.”;
(d) in the heading, for “total top-up amount” substitute “certain top-up amounts”.
(2) In section 228 (minority owned members), after subsection (4) insert—
“(5) But neither subsection (3) nor (4) applies to the reference to “standard member” in section 199(2A) (election to treat top-up amounts of relevant members as nil).”

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/4/paragraph/45 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-4/paragraph-45
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

