Legislation – Finance Act 2024
Schedules
Schedule 12Pillar Two
Part 2Multinational top-up tax
Investment entity tax transparency election
28
In section 213 (investment entity tax transparency election), after subsection (6) insert—
“(6A)
Where, ignoring the election, profits and amounts of qualifying tax expense would be allocated to M in accordance with sections 168 and 178 to 181, those profits and amounts are to be allocated—
(a)
first to M, and then
(b)
to O in proportion to the direct ownership interests O is treated as having in M.”