{
  "url": "https://openlegislation.uk/finance-act-2026/schedule-8/paragraph-32",
  "json_url": "https://openlegislation.uk/finance-act-2026/schedule-8/paragraph-32.json",
  "legislation": "ukpga/2026/11",
  "legislation_title": "Finance Act 2026",
  "legislation_url": "https://openlegislation.uk/finance-act-2026",
  "path": "schedule/8/paragraph/32",
  "kind": "paragraph",
  "number": "32",
  "heading": "Qualifying undertaxed profits tax",
  "text": "(1) For the purposes of Part 3 of F(No.2)A 2023, a tax is to be treated as a qualifying undertaxed profits tax for any accounting period that ends before the first regulations under section 257 of that Act have been made if—\n(a) it is a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules, or\n(b) it is reasonable to conclude that it is likely to be a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules.\n(2) In sub-paragraph (1) “Pillar Two rules” has the same meaning as in Part 3 of F(No.2)A 2023 (see section 255 of that Act).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2026/11/schedule/8/paragraph/32",
    "retrieved_at": "2026-10-29T08:42:24.914774+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}