# Finance Act 2026, Paragraph 38: Domestic top-up tax: allocation of CFC mobile income

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

In section 272 (domestic top-up tax: determining top-up amounts of group member), in subsection (8), for paragraph (d) substitute—
“(d) section 179 (controlled foreign companies) has effect as if for subsection (2) there were substituted—
“(2) But the amount of qualifying current tax expense in respect of mobile income allocated to F is not to exceed 15% of the adjusted profits of F.””

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/8/paragraph/38 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-8/paragraph-38
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.