Legislation – Finance Act 2026
Changes to legislation:
Finance Act 2026, Paragraph 8 is up to date with all changes known to be in force on or before 17 April 2026. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
Changes to Legislation
Revised legislation carried on this site may not be fully up to date. Changes and effects are recorded by our editorial team in lists which can be found in the ‘Changes to Legislation’ area. Where those effects have yet to be applied to the text of the legislation by the editorial team they are also listed alongside the legislation in the affected provisions. Use the ‘more’ link to open the changes and effects relevant to the provision you are viewing.
Changes and effects yet to be applied to Schedule 8 Paragraph 8:
- Pt. 15 excluded by S.I. 2026/331 reg. 19
Changes and effects yet to be applied to the whole Act associated Parts and Chapters:
Whole provisions yet to be inserted into this Act (including any effects on those provisions):
- Pt. 15 excluded by S.I. 2026/331 reg. 19
Schedule 8Pillar Two
Other provision about permanent establishments
8
(1)
Section 232 (permanent establishments) is amended as follows.
(2)
In the heading, omit “treated as entities”.
(3)
In subsection (1)—
(a)
in the words before paragraph (a), omit “that”;
(b)
in paragraph (a), for “is located” substitute “that is situated”
;
(c)
“(aa)
any profits in relation to which are reflected in the financial statements of the main entity, and”;
(d)
in paragraph (b), at the beginning insert “that”
;
(4)
In subsection (2)—
(a)
in paragraphs (b) and (c), for “is in” substitute “is situated in”
;
(b)
“(ii)
the income attributable to the place of business’s operations is exempted from tax by the territory of the main entity or, where the main entity is a flow-through entity, by the territory in which the reference entity (within the meaning of section 168) is located.”
(5)
“(2A)
For the purposes of subsection (1)(a)—
(a)
section 240(2) (flow-through entities treated as stateless) is to be disregarded, and
(b)
a flow-through entity that would otherwise be a stateless entity under section 240(2) is instead treated as located in the territory in which it is created.”
(6)
“(6)
See also section 232ZA (modifications that apply where legal main entity is distinct from main entity).”