Section 229D Amount allocated to the United KingdomF1

Take the following steps to determine the UK proportion of an untaxed amount of a member of a multinational group—

• Step 1

  Determine the number of employees of qualifying members of the group located in the United Kingdom for the accounting period to which the untaxed amount relates (“the relevant period”).

• Step 2

  Determine the total number of employees in the relevant period of qualifying members of the group located in territories (including the United Kingdom) in which a qualifying undertaxed profits tax applies to the untaxed amount.

• Step 3

  Divide the result of Step 1 by the result of Step 2.

• Step 4

  Determine the value of tangible fixed assets of the qualifying members of the group located in the United Kingdom for the relevant period.

• Step 5

  Determine the value of tangible fixed assets of the qualifying members of the group located in territories (including the United Kingdom) in which a qualifying undertaxed profits tax applies to the untaxed amount.

• Step 6

  Divide the result of Step 4 by the result of Step 5.

• Step 7

  Add together the results of Step 3 and Step 6 and divide that sum by 2.

• Step 8

  The UK proportion of the untaxed amount is—

  1. (a)

     if the nil asset value condition is met, the untaxed amount multiplied by the result of Step 3;

  2. (b)

     if the nil employee condition is met, the untaxed amount multiplied by the result of Step 6;

  3. (c)

     in any other case, the untaxed amount multiplied by the result of Step 7.

For the purposes of subsection (1)—

A qualifying undertaxed profits tax applies in a territory in relation to an untaxed amount if—

See sections 229G and 229H for how to determine the number of employees and the value of tangible fixed assets of a qualifying member of a multinational group.