Legislation – Finance Act 2024
Schedules
Schedule 12Pillar Two
Part 2Multinational top-up tax
Substance based income exclusion: inclusion of payroll costs and assets voluntary
22
(1)
In section 196, in subsection (1)—
(a)
omit the “and” after paragraph (c), and
(b)
at the end of paragraph (d) insert
“, and,
(e)
the filing member chooses to include those costs in calculating the substance based income exclusion for the period.”
(2)
In section 197, in subsection (5)—
(a)
in the words before paragraph (a), omit “it is”,
(b)
in paragraph (a), at the beginning insert “it is”
,
(c)
omit the “and” after that paragraph,
(d)
in paragraph (b), at the beginning insert “it is”
, and
(e)
at the end of that paragraph insert
“and,
(c)
the filing member chooses to include the asset in calculating the substance based income exclusion for the period.”