Section 228 Minority owned members

United Kingdom

(1)

For the purposes of this Part, a member of a multinational group is a “minority owned member” if—

(a)

the ultimate parent holds no more than 30% of the ownership interests in that member, and

(b)

the member is not an investment entity.

(2)

If—

(a)

a minority owned member (“M”) holds (directly or indirectly) ownership interests in another minority owned member, and

(b)

no other minority owned member holds (directly or indirectly) ownership interests in M,

M is the minority owned parent of a minority subgroup, and the minority owned members in which M has ownership interests are also members of that group.

(3)

For the purpose of determining the effective tax rate and top-up amounts of members of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to members of that subgroup.

(4)

For the purposes of determining the effective tax rate and top-up amounts of a minority owned member that is not a member of a minority subgroup, this Part applies as if references to standard members of a multinational group were instead to that member.

F1(5)

But neither subsection (3) nor (4) applies to the reference to “standard member” in section 199(2A) (election to treat top-up amounts of relevant members as nil).

Annotations

Textual amendments

F1: S. 228(5) inserted (with effect in accordance with Sch. 4 para. 72(4) of the amending Act) by Finance Act 2025 (c. 8), Sch. 4 paras. 45(2), 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)