Section 229C Allocation of untaxed amount to membersF1

(1)

An untaxed amount of a member of a multinational group is to be allocated to qualifying members of the group located in the United Kingdom by—

(a)

first, determining the amount (“the UK proportion”) of the untaxed amount to be allocated to the group in the United Kingdom in accordance with section 229D, and

(b)

then, allocating an amount of the UK proportion to each qualifying member located in the United Kingdom in accordance with section 229E.

(2)

But no allocation is to be made under subsection (1) if in section 229D(1) the results of both Step 2 and Step 5 are nil.

(3)

For the purposes of this Chapter, a member of a multinational group is qualifying unless it is—

(a)

an investment entity, F2...

(b)

a member of a joint venture group F3, or

(c)

a securitisation company within the meaning of the Taxation of Securitisation Companies Regulations 2006 (S.I. 2006/3296).

Annotations

Textual amendments

F1: Pt. 3 Ch. 9A inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 5, 10
F2: Word in s. 229C(3)(a) omitted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 24(a), 53(5)-(13)
F3: S. 229C(3)(c) and word inserted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 24(b), 53(5)-(13)

Notes on Part 3

Modifications

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