Section 189 Deemed distribution tax election

United Kingdom

(1)

The filing member of a multinational group may make an election that section 190 (deemed distribution tax) applies to all of the standard members of the group in a particular territory for an accounting period.

(2)

An election under subsection (1) may only be made in relation to a territory if that territory has an eligible distribution tax system.

(3)

In this Part “eligible distribution tax system” means a system of tax on company profits that—

(a)

is generally only payable when a company distributes, or is deemed to distribute, those profits to its members, or when it incurs certain non-business expenses,

(b)

is charged at a rate of at least 15%, and

(c)

was in force on or before 1 July 2021.

(4)

Paragraph 2 of Schedule 15 (annual elections) applies to an election under this section.

Notes on Part 3

Modifications

C1: Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3)