{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/schedule-16A/paragraph-7",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/schedule-16A/paragraph-7.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "schedule/16A/paragraph/7",
  "kind": "paragraph",
  "number": "7",
  "heading": "No untaxed amounts for groups in initial phase of international expansion",
  "text": "(1) This paragraph applies to a multinational group for an accounting period if—\n(a) it meets the international expansion condition for that period, and\n(b) the accounting period is the first accounting period in which the group came within the scope of Chapter 9A, or any of the following 4 accounting periods.\n(2) If this paragraph applies to a multinational group for an accounting period—\n(a) no member of the group has an untaxed amount relating to that period, and\n(b) no joint venture group has an untaxed amount in relation to the multinational group relating to that period.\n(3) A multinational group meets the international expansion condition for an accounting period if—\n(a) the group does not have members located in more than 6 territories, and\n(b) the sum of the values of tangible fixed assets of qualifying members of the group, other than members located in the reference territory, for that period does not exceed 50 million euros.\n(4) For the purposes of this paragraph—\n(a) the value of tangible fixed assets of a qualifying member of a multinational group is to be determined in accordance with section 229H, and\n(b) the “reference territory” is the territory for which the sum of the values of tangible fixed assets of qualifying members of the group located in that territory is greatest.\n(5) The first accounting period in which a multinational group comes within the scope of Chapter 9A is the later of—\n(a) the first accounting period for which it meets Condition A in section 129(2) (annual revenue exceeds 750 million euros), and\n(b) the first accounting period beginning on or after the day on which section 229C (allocation of untaxed amount to members) comes into force for any purpose.\n(6) For the purposes of this paragraph, “territory” does not include the nominal territory of a stateless member of a multinational group (see section 132(3)(b)).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 16A Pt. 2 inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 6(5), 10"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Sch. 16A para. 7(6) 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. 27, 53(5)-(13)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/schedule/16A/paragraph/7",
    "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."
}