180 Blended CFC regimes

180  Blended CFC regimes

(1)     This section applies to accounting periods commencing on or before 31 December 2025 that end on or before 30 June 2027.

(2)     Subsection (3) applies where—

(a)     a member of a multinational group (“C”) is subject to a blended CFC regime in an accounting period (“the relevant period”),

(b)     C has an ownership interest in an entity (“F”) that is a . . . CFC entity in relation to C, and

(c)     the blended CFC allocation key of F is greater than nil.

(3)     The appropriate proportion of tax charged to C under that regime (after all deductions and use of any losses) is—

(a)     where F is a member of the same multinational group as C, to be allocated to F, or

(b)     where F is not a member of that group, to be excluded from the covered tax balance of C.

(4)     The appropriate proportion is

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