Part 2 Transitional Safe Harbour
Finance (No 2) Act 2023 (2023 c 30) | Legislation

Part 2 Transitional Safe Harbour

Chapter 1
Transitional Safe Harbour Election

Election

3

[(1)     The filing member of a multinational group may make a transitional safe harbour election for an accounting period in respect of a territory.

(1A)     The effect of the election is that all of the standard members of the group located in the territory are to be treated as not having top-up amounts or additional top-up amounts for the purpose of determining the liability of any member of the group to multinational top-up tax.]

(2)     An election may only be made for an accounting period if—

(a)     the period commences on or before 31 December 2026 and ends on or before 30 June 2028,

(b)     a qualifying country-by-country report has been prepared in relation to the territory for the period,

(c)     the election has been made in respect of the territory for each preceding accounting period—

(i)     that commenced on or after 31 December 2023, and

(ii)     in which the Pillar Two rules [would, ignoring any transitional safe harbour election, have applied to any member] of the group in the territory,

(d)     an election under section 189 (deemed distribution tax election) has not been

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