{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/section-167",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/section-167.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "section/167",
  "kind": "section",
  "number": "167",
  "heading": "Underlying profits of hybrids",
  "text": "(1) This section applies where a member of a multinational group (“M”)—\n(a) is not regarded as tax transparent in the territory in which it is located, and\n(b) is regarded as tax transparent in a territory in which a member of the group with an ownership interest in it (“G”) is located.\n(2) Where—\n(a) the adjusted profits of G reflect profits of M, and\n(b) the basis for the profits of M being so reflected is that M (along with any other entities through which G holds that interest) is regarded as tax transparent in the territory in which G is located,\nsuch profits as are reflected on that basis are to be allocated to M (and included in the adjusted profits of M to the extent not already included) and excluded from the adjusted profits of G.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/section/167",
    "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."
}