{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/section-122",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/section-122.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "section/122",
  "kind": "section",
  "number": "122",
  "heading": "Chargeable persons",
  "text": "(1) A person is chargeable to multinational top-up tax for an accounting period of a multinational group if the group is a qualifying multinational group in that period and—\n(a) the person—\n(i) is a ... member of the multinational group at any time in that period,\n(ii) is a body corporate or a partnership ..., and\n(iii) is located in the United Kingdom, or\n(b) the person is chargeable to tax in respect of an entity that is a ... member of the multinational group at any time in that period.\n(2) A person is chargeable to tax in respect of a ... member of a multinational group if—\n(a) the profits of the ... member would, on the relevant assumptions, be the profits of the person for the purposes of income tax or corporation tax,\n(b) the ... member is located in the United Kingdom, and\n(c) the ... member is not—\n(i) a body corporate, or\n(ii) a partnership ....\n(3) The relevant assumptions are—\n(a) that the ... member has profits that are chargeable to income tax or corporation tax, and\n(b) that the person is resident in the United Kingdom for the purposes of that tax.\n(4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(7) Where more than one person is chargeable to tax in relation to the same ... member of a qualifying multinational group as a result of the application of subsection (2), each of those persons is jointly and severally liable to multinational top-up tax.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Word in s. 122(1) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(2), 10"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 122(1)(a)(ii) omitted (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 virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(a)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Word in s. 122(2) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(3), 10"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "Words in s. 122(2)(c)(ii) omitted (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 virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(b)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Word in s. 122(3)(a) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(4), 10"
    },
    {
      "type": "F",
      "label": "F6",
      "text": "S. 122(4)-(6) omitted (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 virtue of Finance Act 2024 (c. 3), Sch. 12 para. 2(1)(c)"
    },
    {
      "type": "F",
      "label": "F7",
      "text": "Word in s. 122(7) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 3(5), 10"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/section/122",
    "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."
}