Section 237 Intermediate and partially-owned parent members

United Kingdom

(1)

A member of a multinational group is a partially-owned parent member of that group if—

(a)

it is not a permanent establishment, investment entity or the ultimate parent,

F1(b)

it has—

(i)

a direct or indirect ownership interest in another member of the group, or

(ii)

a permanent establishment, and

(c)

more than 20% of the ownership interests that represent an entitlement to a share of the profits of the member are held by persons that are not members of the group.

(2)

A member of a multinational group is an intermediate parent member of the group if—

(a)

it is not a permanent establishment, investment entity, a partially-owned parent member or the ultimate parent, and

F2(b)

it has—

(i)

a direct or indirect ownership interest in another member of the group, or

(ii)

a permanent establishment.

Annotations

Textual amendments

F1: S. 237(1)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 3(2), 53(5)-(13)
F2: S. 237(2)(b) substituted (with effect in accordance with Sch. 8 para. 53(5)-(13) of the amending Act) by Finance Act 2026 (c. 11), Sch. 8 paras. 3(3), 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)