Legislation – Finance Act 2026
Changes to legislation:
Finance Act 2026, Paragraph 22 is up to date with all changes known to be in force on or before 18 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 22:
- 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
Deferred tax assets and liabilities: exclusions
22
(1)
Schedule 16A (safe harbours) is amended as follows.
(2)
In paragraph 3 (disqualifying conditions)—
(a)
in sub-paragraph (1), for “Conditions A to D” substitute “The following conditions”
;
(b)
“(7)
Condition E is that—
(a)
a member of the group located in the territory has a relevant pre-entry deferred tax asset or relevant pre-entry deferred tax liability, and
(b)
the qualifying domestic top-up tax applying in the territory either—
(i)
(ii)
makes such corresponding provision in a way that is inconsistent with the Pillar Two commentary in relation to relevant pre-entry deferred tax assets or relevant pre-entry deferred tax liabilities.
(8)
In subsection (7) “relevant pre-entry deferred tax asset” and “relevant pre-entry deferred tax liability” have the same meaning as in Schedule 16, but for that purpose the words “or (7C)” in the definition of “relevant pre-entry deferred tax asset” are to be disregarded.”
(3)
In paragraph 4(1)—
(a)
omit paragraph (a);
(b)
in paragraph (b)—
(i)
for “after sub-paragraph (6), there were inserted” substitute “at the end there were inserted the following disqualifying condition”
;
(ii)
the inserted sub-paragraph (7) becomes an inserted unnumbered sub-paragraph.
(4)
In paragraph 5(1)(b)—
(a)
omit sub-paragraph (i);
(b)
in sub-paragraph (ii)—
(i)
for “after sub-paragraph (6), there were inserted” substitute “at the end there were inserted the following disqualifying condition”
;
(ii)
the inserted sub-paragraph (7) becomes an inserted unnumbered sub-paragraph.