# Finance (No. 2) Act 2023, Section 189: Deemed distribution tax election

Extent: E+W+S+N.I.

(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.

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Source: https://www.legislation.gov.uk/ukpga/2023/30/section/189 (the official version)
Page: https://openlegislation.uk/finance-no-2-act-2023/section-189
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

