Section 238 Tax transparency of entities
United Kingdom
An entity is regarded as tax transparent in a territory F1to the extent that the territory treats the income, expenditure, profits F2or losses of the entity, for the purposes of covered taxes, as the income, expenditure, profits or losses of the direct owner of the entity in proportion to its interest in the entity.
Annotations
Textual amendments
- F1
Words in s. 238 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(10)(a)
- F2
Word in s. 238 substituted (22.2.2024 with effect for accounting periods beginning on or after 31.12.2023 in accordance with Sch. 12 para. 1(2) of the amending Act) by Finance Act 2024 (c. 3), Sch. 12 para. 14(10)(b)
Notes on Part 3
Modifications
- C1
Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3)