{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/schedule-16/paragraph-12A",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/schedule-16/paragraph-12A.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "schedule/16/paragraph/12A",
  "kind": "paragraph",
  "number": "12A",
  "heading": "Election",
  "text": "(1) The filing member of a multinational group may elect for an accounting period that in the territory of the ultimate parent—\n(a) no member of the group located in the territory has an untaxed amount relating to that period, and\n(b) no joint venture group whose joint venture parent is located in the territory has an untaxed amount in relation to the multinational group relating to that period.\n(2) An election may only be made for an accounting period if—\n(a) the minimum corporate tax rate for the territory of the ultimate parent is equal to, or in excess of, 20%, and\n(b) the accounting period—\n(i) commenced on or before 31 December 2025 and ends before 31 December 2026, and\n(ii) is not longer than 12 months.\n(3) The “minimum corporate tax rate” for a territory means—\n(a) in the case of a territory in which corporate income tax may be imposed by subdivisions of that territory as well as by a national authority, the sum of—\n(i) the nominal national rate that generally applies, and\n(ii) the lowest nominal rate that generally applies that is imposed by a subdivision of that territory (and where one or more subdivisions do not impose corporate income tax, that rate will be zero), or\n(b) otherwise, the nominal rate that generally applies.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 16 Pt. 2A inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(4), 10"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/schedule/16/paragraph/12A",
    "retrieved_at": "2026-10-29T08:52:11.242356+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."
}