Legislation – Finance Act 2026
Changes to legislation:
Finance Act 2026, Paragraph 37 is up to date with all changes known to be in force on or before 19 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.
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Changes and effects yet to be applied to Schedule 8 Paragraph 37:
- 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
Domestic top-up tax: covered tax to include group relief payments
37
In subsection (8)—
(a)
“(aa)
section 138 (profits adjusted to be before tax) has effect as if at the end of subsection (2) there were inserted—“(g)
a group relief payment so far as excluded (and for that purpose “group relief payment” and “excluded” have the meaning given in section 173(3)).”;
(ab)
section 173 (covered taxes) has effect, subject to paragraph (f) below, as if (in addition to the modification made by subsection (4)(a))—
(i)
in subsection (1), the “and” after paragraph (c) were omitted and after paragraph (d) there were inserted“, and(e)
a group relief payment so far as it is not excluded.”;
(ii)
at the end there were inserted—“(3)
For the purposes of subsection (1)(e)—
(a)
“group relief payment” means a payment—
(i)
in relation to which section 183 or 188FA of CTA 2010 applies to the member, and
(ii)
that relates to group relief which the member claims under section 130 or 188CB of that Act by virtue of the group condition being met (see sections 132 and 188CE of that Act);
(b)
a group relief payment is “excluded” so far as it exceeds 15% of the agreed loss amounts (within the meaning of section 183 or 188FA of that Act, as the case may be) to which the group relief payment relates.
(4)
It follows from subsection (1)(e) that a group relief payment, so far as not excluded, operates to reduce the covered tax balance of the recipient.”
(b)
“(f)
section 239(4)(a) (location of entities: tie-breaker by reference to covered taxes) has effect without the modification made by paragraph (ab).”