{
  "url": "https://openlegislation.uk/finance-no-2-act-2023/section-189",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2023/section-189.json",
  "legislation": "ukpga/2023/30",
  "legislation_title": "Finance (No. 2) Act 2023",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2023",
  "path": "section/189",
  "kind": "section",
  "number": "189",
  "heading": "Deemed distribution tax election",
  "text": "(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.\n(2) An election under subsection (1) may only be made in relation to a territory if that territory has an eligible distribution tax system.\n(3) In this Part “eligible distribution tax system” means a system of tax on company profits that—\n(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,\n(b) is charged at a rate of at least 15%, and\n(c) was in force on or before 1 July 2021.\n(4) Paragraph 2 of Schedule 15 (annual elections) applies to an election under this section.",
  "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/189",
    "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."
}