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Section 222 Investment entity effective tax rate

United Kingdom

The investment entity effective tax rate in a territory for an accounting period is determined by taking the following steps—

  • Step 1

    Determine the adjusted profits made by each of the investment entities in the territory, as determined under Chapter 4 and adjusted under section 223.

  • Step 2

    Subtract the sum of the losses of those investment entities that made a loss in that period from the sum of the profits of those investment entities that made a profit in that period.

  • Step 3

    If the result of Step 2 is nil or less, the investment entity effective tax rate is to be treated as 15%. Otherwise, proceed to Step 4.

  • Step 4

    Determine the covered tax balance of each such investment entity in accordance with Chapter 5.

  • Step 5

    Adjust the amounts determined in Step 4 in accordance with section 223 (to the extent applicable).

  • Step 6

    Add together the amounts determined in Step 5 that are adjusted positive covered tax balances.

  • Step 7

    Add together the amounts determined in Step 5 that are adjusted negative covered tax balances.

  • Step 8

    Subtract the result of Step 7 from the result of Step 6.

  • Step 9

    Divide the result of Step 8 by the result of F1Step 2. This is the investment entity effective tax rate.

Annotations

Textual amendments

F1

Words in s. 222 substituted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 67, 72(4)

Notes on Part 3

Modifications

C1

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