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Paragraph 12 De minimis testF1

(1)

For the purposes of paragraph 8(2)(c), “the de minimis test” is met for an accounting period if, on the assumption in sub-paragraph (2), an election under section 199 (de minimis exclusion) could be made for the period for the relevant territory.

(2)

The assumption is that for the period in question—

(a)

the revenue of each specified member, and

(b)

the adjusted profits of each specified member,

is or are equal to the revenue of that member as it would be determined under the country-by-country reporting rules.

Annotations

Textual amendments

F1

Sch. 16A Pt. 3 inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 39, 53(5)-(13)

Notes on Schedule 16A

Textual amendments

F1

Sch. 16A inserted (with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 41(1)