Multinational Top-up Tax and Domestic Top-up Tax

MTT62130 - Charging mechanisms: Undertaxed Profits Rule: Chargeability for investment entities

An investment entity can be undertaxed and have an untaxed amount. However, an investment entity is not a qualifying member for the purposes of allocating and charging the untaxed amount to members of a group.

The effect of this is that an investment entity can contribute to the total untaxed amount of a group but will not be chargeable to UTPR. In effect, its untaxed amounts are attributed to other members of the group.

This is set out in sections 123 and 229C Finance (No.2) Act 2023.