Part 3 Others

United Kingdom

1. 11Permanent establishments as excluded entities
2. 12Use of substituted values
3. 13Flow-through entities
4. 14Flow-through entities
5. 15Flow-through entities
6. 16Flow-through entities
7. 17Flow-through entities
8. 18Tax equity partnerships
9. 19Tax equity partnerships
10. 20Tax equity partnerships
11. 21Tax equity partnerships
12. 22Tax equity partnerships
13. 23Tax equity partnerships
14. 24Tax equity partnerships
15. 25Blended CFC regimes
16. 26No allocation of deferred tax assets and liabilities under blended CFC regimes
17. 27Cross-border allocation of current tax under cross-crediting regimes
18. 28Cross-border allocation of deferred tax
19. 29Extension of qualifying foreign tax credits
20. 30Deferred tax recapture
21. 31Existing deferred tax assets and liabilities arising under blended CFC regimes
22. 32Substance based income exclusion: permanent establishments and flow-through entities
23. 33Substance based income exclusion: permanent establishments and flow-through entities
24. 34Substance based income exclusion: permanent establishments and flow-through entities
25. 35Substance based income exclusion: permanent establishments and flow-through entities
26. 36Eligible payroll costs
27. 37Additional top-up amounts
28. 38Additional top-up amounts
29. 39Joint ventures
30. 40Joint ventures
31. 41Joint ventures
32. 42Domestic top-up tax
33. 43Domestic top-up tax
34. 44Domestic top-up tax: excluded entities
35. 45De minimis rule
36. 46Transitional safe harbour
37. 47Transitional safe harbour: arbitrage arrangements
38. 48Substance based income exclusion: removal of provision for election
39. 49Inclusion ratio
40. 50Inclusion ratio
41. 51Specification of territories and taxes
42. 52Filing etc not required before 30 June 2026
43. 53Minor amendments
44. 54Minor amendments
45. 55Minor amendments
46. 56Minor amendments
47. 57Minor amendments
48. 58Minor amendments
49. 59Minor amendments
50. 60Minor amendments
51. 61Minor amendments
52. 62Minor amendments
53. 63Minor amendments
54. 64Minor amendments
55. 65Minor amendments
56. 66Minor amendments
57. 67Minor amendments
58. 68Minor amendments
59. 69Minor amendments
60. 70Minor amendments
61. 71Minor amendments
62. 72Commencement