{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/section-169",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/section-169.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "section/169",
  "kind": "section",
  "number": "169",
  "heading": "Certain non tax resident entities to be treated as flow-through entities",
  "text": "(1) This section applies to a member of a multinational group that—\n(a) is not tax resident in any territory,\n(b) is not subject to covered taxes,\n(c) does not have a place of business in the territory where it is created, and\n(d) is not regarded as tax transparent in the territory in which it is created.\n(2) A member of a multinational group to which this section applies is to be treated as being regarded as tax transparent in the territory it is created in to the extent that—\n(a) it is regarded as tax transparent in the territory in which holders of direct ownership interests in the member are located, and\n(b) its income, expenditure, profits and losses are not attributable to a permanent establishment.\n(3) Accordingly, such a member is to be treated as a flow-through entity.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Word in s. 169(2) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(a), 72(4)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 169(2)(a) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(b)(i), 72(4)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 169(2)(a) substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 14(b)(ii), 72(4)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2023/30/section/169",
    "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."
}