- a designated deposit scheme
means a deposit scheme which is designated, for the purposes of this section, by regulations made by the Commissioners. 2 A “deposit scheme” means a scheme which is established— a by regulations under Schedule 8 to the Environment Act 2021, or b by or under any other enactment that makes similar provision for a returnable deposit to be paid in relation to goods. 3 In subsection (2)(b), the reference to an “enactment” includes a reference to an enactment comprised in, or in an instrument made under— a an Act of the Scottish Parliament, b a Measure or Act of Senedd Cymru, or c Northern Ireland legislation. 4 Section 97(5) (statutory instruments: procedure) does not apply to a statutory instrument containing only regulations under subsection (1). 55C 1 This section applies if— a a taxable person makes a taxable (but not a zero-rated) supply of goods, and b a deposit amount is payable in relation to the goods supplied. 2 For the purposes of this section and section 55D, a “deposit amount” in relation to goods is an amount that, in accordance with the provisions of a designated deposit scheme— a is added to the price payable for the goods, and b must be rep
- a transfer of assets
includes a transaction that relates to assets that does not result in a change in their ownership if the transaction has a similar effect for accounting purposes to a change in ownership of those assets;
- a withheld amount
means an amount that HMRC would, apart from this section, be required or permitted to pay to a person.
- acceptable accounting standards
means—
- Acceptable overseas GAAP
means the generally accepted accounting practice and principles of any of the following— • Australia;
- accounting currency
means the currency of the main economic environment in which a member of a multinational group operates;
- activities
includes, in particular, packaging and processing, or carrying out other operations on or in relation to, the alcoholic products.
- added sugar ingredients
means anything within paragraph (a) or (b) of section 29(2).”
- alcohol
means ethanol.
- alcoholic product
means any of the following—
- all relevant information
means all of the information described in paragraphs (a) to (d) of paragraph 4(3).
- Allowable costs
means—
- annual accounting scheme instalment
means an amount payable to HMRC by virtue of regulation 50(2)(a) of the VAT Regulations.”
- appeal period
means the period during which—
- appeal tribunal
has the same meaning as in Chapter 2 of Part 1 of the FA 1994.
- appropriate authority
means—
- approved wholesaler
means a person approved under this section to carry on a controlled activity.
- AR
means, in relation to a company— (a) in a case where corporation tax is charged at the standard small profits rate on the company’s taxable total profits of the accounting period mentioned in subsection (1) which are not ring fence profits, that rate, or (b) in any other case, the main rate of corporation tax.”
- arrangements
means any scheme, transaction or series of transactions;
- asset
means an asset within the scope of the dormant assets scheme (see section 1(6) of the 2022 Act);
- authorised reclaim fund
has the same meaning as in the Dormant Assets Acts 2008 to 2022;
- basic payment scheme
means Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17 December 2013 establishing rules for direct payments to farmers under support schemes within the framework of the common agricultural policy and repealing Council Regulation (EC) No 637/2008 and Council Regulation (EC) No 73/2009;
- Beer
means—
- Beer-based beverage
means a beverage which is a mixture of beer and any of the following—
- bilateral safeguarding investigation
means an investigation under paragraph 6 of Schedule 5 as that provision applies by virtue of this Schedule;
- bilateral safeguarding remedy
has the meaning given in paragraph 23(4)(a) of Schedule 5 as that provision applies by virtue of this Schedule;
- blended CFC regime
means a controlled foreign company tax regime— (a) under which the income, losses and creditable taxes of all of the controlled foreign companies of the entity with ownership interests in them are aggregated for the purposes of calculating the entity’s tax liability under the regime, (b) that does not take into account the income of the entity, or members of a consolidated group of which the entity is a member, that arises in the location of the entity, apart from to the extent the entity may use its losses arising in that location to reduce its liability under the regime, and (c) which operates by reference to a rate which reflects a threshold for low taxation.
- carrying value
means the carrying value of the asset including— but not including any positive difference between the value of an asset recorded from time to time and the value of an asset when it was acquired by the member, where that difference is solely attributable to a revaluation.
- Cider
means a product which—
- claim notification
means, in relation to an R&D claim, a notification made by the company to an officer of His Majesty’s Revenue and Customs in accordance with regulations under subsection (2);
- claim notification period
means, in relation to an R&D claim, the period— (a) beginning with the first day of the period of account which is the same as the accounting period in respect of which the claim is made, or within which that accounting period falls, and (b) ending with the last day of the period of six months beginning with the first day after that period of account. 2 The Commissioners for His Majesty’s Revenue and Customs may by regulations specify, in relation to a claim notification— a information to be provided with the notification;
- closure notice
means a partial closure notice or a final closure notice.
- commencement date
means the date mentioned in subsection (2) or (3);
- company
has the meaning it has in the Corporation Tax Acts (see section 1121 of CTA 2010);
- consolidated group
means the following entities (which are its members)—
- consumer prices index
means the all items consumer prices index published by the Statistics Board.”
- control
has the same meaning as in section 1124 of CTA 2010.”
- Controlled activity
means—
- controlled foreign company tax regime
means a set of tax rules (other than multinational top-up tax or any tax equivalent to multinational top-up tax) under which an entity with an ownership interest in another entity located in a different territory (“the controlled foreign company”) is subject to current taxation on its share of part or all of the income earned by the controlled foreign company, irrespective of whether that income is distributed currently to it;
- cooperative
means an entity that collectively markets or acquires goods or services on behalf of its members and that is subject to a tax regime in the territory in which it is located that is designed to ensure tax neutrality in respect of— (a) property or services of the members sold through the cooperative, or (b) property or services acquired by members through the cooperative;
- country-by-country report
means a country-by-country report in respect of a multinational group that is prepared and filed in accordance with legislation implementing the OECD’s guidance on country-by-country reporting.
- covered bond vehicle
has the meaning given by paragraph 53(7) of Schedule 19 to FA 2011.
- cross-border deferred taxes guidance
means Chapter 4.2 of Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), June 2024 published by the OECD on 17 June 2024.
- cross-crediting guidance
means Chapter 3.1 of Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), June 2024 published by the OECD on 17 June 2024.
- cross-crediting regime methodology
means—
- de minimis aggregate income
means aggregate income of an estate which is treated as bearing income tax at 0% because of section 963(1A).”
- deemed distribution
has the meaning given by section 215(4)(c);
- deferred taxes methodology
means—
- definitive bilateral safeguarding amount
means the additional amount of import duty mentioned in paragraph 16(3)(a) of Schedule 5 as that provision applies by virtue of this Schedule. • “definitive suspension of tariff rate reduction” has the meaning given in paragraph (aa) of paragraph 16(3) of Schedule 5 (see paragraph 11(1)(a));
- definitive suspension of tariff rate reduction
has the meaning given in paragraph (aa) of paragraph 16(3) of Schedule 5 (see paragraph 11(1)(a));
- Denatured alcohol
means an alcoholic product which has been mixed with a substance, and in a manner, specified by or under regulations made by the Commissioners (and references, however expressed, to “denaturing” alcoholic products are to be construed accordingly).
- deposit scheme
means a scheme which is established— a by regulations under Schedule 8 to the Environment Act 2021, or b by or under any other enactment that makes similar provision for a returnable deposit to be paid in relation to goods. 3 In subsection (2)(b), the reference to an “enactment” includes a reference to an enactment comprised in, or in an instrument made under— a an Act of the Scottish Parliament, b a Measure or Act of Senedd Cymru, or c Northern Ireland legislation. 4 Section 97(5) (statutory instruments: procedure) does not apply to a statutory instrument containing only regulations under subsection (1). 55C 1 This section applies if— a a taxable person makes a taxable (but not a zero-rated) supply of goods, and b a deposit amount is payable in relation to the goods supplied. 2 For the purposes of this section and section 55D, a “deposit amount” in relation to goods is an amount that, in accordance with the provisions of a designated deposit scheme— a is added to the price payable for the goods, and b must be repaid by a person, if the conditions for repayment under the scheme are met. 3 The deposit amount is to be disregarded in determining the amount of the cons
- derivative contract
means— (a) a derivative contract within the meaning of Part 7 of CTA 2009 (see section 576 of that Act), or (b) a contract which is not a derivative contract within the meaning of that Part only as a result of section 589(2)(b) of that Act (general exclusion of contracts whose underlying subject matter consists of shares);”
- designated person
has the meaning given by section 9 of SAMLA 2018;
- devalued tax attribute
means a tax attribute of a member of a multinational group—
- DIIR
means a tax which—
- disallowed accrual
means— (a) any movement in deferred tax expense reflected in the member’s underlying profits which relates to an uncertain tax position, or (b) any movement in deferred tax expense reflected in those profits which relates to distributions from another member of that group;
- domestic leg of an international voyage
means the transportation of passengers or cargo by ship between two locations in a single territory in circumstances where the ship’s overall voyage has proceeded from or will continue to a different territory;
- dual-listed arrangement
means an arrangement entered into by two or more ultimate parents of consolidated groups to combine their businesses by contract (rather than by the holding of ownership interests in one another) where the following conditions are met— (a) the arrangements provide for the ultimate parents of the groups to make distributions (with respect to dividends and in liquidation) to their shareholders based on a fixed ratio, (b) the arrangements provide for the management of those businesses as a single economic entity while retaining their separate legal identities, (c) ownership interests in the ultimate parents are quoted, traded or transferred independently in different capital markets, and (d) one of those ultimate parents prepares, or together those parents prepare, consolidated financial statements— (a) in which the assets, liabilities, income, expenses and cash flows of the controlled entities of those consolidated groups are presented together as those of a single economic unit, and (b) that are required by a regulatory regime to be externally audited;
- duty shortfall
means—
- eligibility conditions
means the conditions in regulation 5 of the lump sum exit scheme;
- eligible distribution tax system
means a system of tax on company profits that—
- eligible expenditure
means expenditure— a to which the claim mentioned in sub-paragraph (2)(a) relates, and b in respect of which the company is entitled to R&D expenditure credit. 5 A claim to which this Part of this Schedule applies may be made, amended or withdrawn after the end of the period mentioned in sub-paragraph (1) or (3) (as the case may be) if an officer of Revenue and Customs allows it.”
- emissions
has the same meaning as it has in the Climate Change Act 2008 (see section 97), • “fossil fuel” has the meaning given by section 32M of the Electricity Act 1989, and • “greenhouse gas” has the same meaning as it has in the Climate Change Act 2008 (see section 92).”
- employee
means— and “employment” is to be construed accordingly.
- Enactment
includes an enactment contained in—
- entity
means—
- excise duty point
has the meaning given by section 1 of F(No. 2)A 1992.
- Excluded dividends
means—
- Excluded equity gain or loss
means any gain, profit or loss arising from—
- excluded liability
means a tax expense attributable to changes in associated deferred tax liabilities in respect of—
- facility
means a platform, an oil well, a platform well, an oil well head or upstream petroleum infrastructure,”
- feed-in tariff export payments
means export payments within the meaning of Schedule A to Condition 33 of the standard conditions of electricity supply licences;
- financial year
means a period of twelve months ending with 31st March.
- Flow-through tax benefits
means— that are made available to be used by an investor in a tax equity partnership arrangement under that arrangement (whether or not those credits or losses are used by the investor).
- food and drink flavourings
means any qualifying flavourings which are for use in— (a) the preparation of food for human consumption, or (b) the preparation of any beverage of an alcoholic strength not exceeding 1.2%;
- for accounting purposes
means for the purposes of accounts drawn up in accordance with acceptable accounting standards;
- for tax purposes
means for the purposes of income tax, corporation tax, multinational top-up tax or domestic top-up tax.
- foreign IIR election
means an election—
- fossil fuel
has the meaning given by section 32M of the Electricity Act 1989, and • “greenhouse gas” has the same meaning as it has in the Climate Change Act 2008 (see section 92).”
- free trade agreement
has the meaning given in section 5(1) of the Trade Act 2021;
- general partner
includes a partner of such an entity that corresponds to a general partner.
- generating undertaking
means— (a) a company, other than a company that is a member of a group, that operates a relevant generating station, or (b) a group of companies that includes at least one member who operates a relevant generating station;
- generation receipts
means amounts that it is fair and reasonable to attribute to generation attributed under section 282(1) (whether or not they are received by, or otherwise arise to the operator of the station) on the basis that the amounts reflect, directly or indirectly, the amount realised (or to be realised) for the wholesale purchase of electricity arising from that generation (whether or not the electricity is actually generated).
- greenhouse gas
has the same meaning as it has in the Climate Change Act 2008 (see section 92).”
- group
(other than in the expression “multinational group”) means a consolidated group (see section 126(2) in Part 3).
- 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);
- held for sale
has the meaning given by international accounting standards;
- HMRC
means His Majesty’s Revenue and Customs;
- international accounting standards
means those standards as issued or adopted, from time to time, by the International Accounting Standards Board;
- International organisation
means an intergovernmental or supranational organisation, or an entity that acts for, is part of, or is wholly owned by such an organisation, provided—
- international shipping
means the transportation of passengers or cargo by ship between different territories;
- international tax compliance arrangements
means any provision of—
- intra-group financing arrangement
means an arrangement between two or more members of a multinational group under which a member (member A) directly or indirectly provides credit or otherwise makes an investment in another member (member B);
- Isle of Man approved wholesaler
means an Isle of Man person who is approved under any provision of the law in force in the Isle of Man corresponding to section 100;
- Isle of Man person
means a person who is established in the Isle of Man for the purposes of value added tax under any provision of the law in force in the Isle of Man corresponding to paragraph 1(10) of Schedule 1 to VATA 1994;
- Jobs Growth Wales Plus scheme
means the scheme under section 14 of the Education Act 2002 known as Jobs Growth Wales Plus.”
- joint venture group
means a joint venture parent of a qualifying multinational group and its joint venture subsidiaries (together its “members”).
- joint venture undertaking
means a generating undertaking—
- large draught container
means a container which—
- licensed distribution system
means a distribution system operated by the holder of a licence under— (a) section 6(1)(c) of the Electricity Act 1989, or (b) Article 10(1)(bb) of the Electricity (Northern Ireland) Order 1992;
- licensed transmission system
means a transmission system operated by the holder of a licence under— (a) section 6(1)(b) of the Electricity Act 1989, or (b) Article 10(1)(b) of the Electricity (Northern Ireland) Order 1992;
- life assurance business
means—
- limited partnership
includes an entity established under the law of a territory outside the United Kingdom that is equivalent to a limited partnership, and
- local tangible asset
means immovable property in the same territory as the member disposing of it is located.
- local tax attributes
means any tax attributes (which may include foreign tax credits) of the member that are recognised under the law of the territory in which the member is located (whether or not such tax attributes are excluded from the member’s covered tax balance).
- lump sum exit scheme
means the Agriculture (Lump Sum Payment) (England) Regulations 2022 (S.I. 2022/390);
- medical article
has the same meaning as in section 76.
- merger
means any arrangement that results in all, or substantially all, of the members of two or more consolidated groups becoming members of a single consolidated group.
- mobile income
means income of a type mentioned in subsection (4) in respect of which a member of a multinational group is subject to tax—
- multi-parent consolidated financial statements
means— (a) in relation to a multi-parent group that is a multi-parent group as a result of a stapled structure, the consolidated financial statements referred to in paragraph (c) of the definition of stapled structure, or (b) in relation to a multi-parent group that is a multi-parent group as a result of a dual-listed arrangement, the consolidated financial statements referred to in paragraph (d) of the definition of dual-listed arrangement.
- multi-vehicle arrangements
means arrangements comprising two or more funds under which an investor in one of those funds would reasonably regard that investment as an investment in the arrangements as a whole rather than exclusively in any particular fund;”
- non-FTE entity
means an entity that is not a flow-through entity.
- non-qualifying gain or loss
means a gain or loss of the transferor on the transfer of assets or liabilities, and is the lesser of—
- officer
means—
- ordinary share capital
has the meaning it has in the Corporation Tax Acts (see section 1119 of CTA 2010). 138ZB 1 Where this section applies (see section 138ZA), a security falling within subsection (2) is to be treated for the purposes of this Act as situated in the United Kingdom (whether or not it would otherwise be so treated) if— a it is held by P, other than as a result of a disposal of the security by P’s spouse or civil partner (“S”) to P to which section 58 (no loss or gain on disposals between spouses or civil partners) did not apply, or b is held by S, other than as a result of a disposal of the security by P to S to which that section did not apply. 2 Those securities are as follows— a the exchanged shares or debentures;
- Other fermented product
means a product which—
- overseas REIT equivalent
means an entity resident in a territory outside the United Kingdom that is the equivalent of a UK REIT;
- ownership interest
means a direct ownership interest or an indirect ownership interest.
- patronage dividend
means a distribution by a cooperative to its members.
- permitted substance
means a substance that—
- Pillar Two commentary
means the following— (a) the commentary on the Pillar Two model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two)”, and (b) the examples illustrating the application of the Pillar Two model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) Examples”.
- Pillar Two model rules
means the model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS”;
- Pillar Two territory
means the United Kingdom and every other territory specified as such in, or in accordance with, regulations made by the Treasury.
- place of business
means a place of business as construed in accordance with the OECD tax model, and includes a deemed place of business for the purpose of that model, a tax treaty or the domestic law of a territory.
- post-commencement devolved enactment
means an enactment which is—
- Post-merger production group
means the production group that consists of— and references to “post-merger production group premises” are to premises within paragraph (a) or (b).
- post-transfer period
means the period beginning with the day on which the member became or (as the case may be) ceased to be a member of a multinational group and ending with the last day of the transfer period.
- pre-2026 election
means an election which specifies an accounting period ending before 31 December 2025 as—
- Pre-fermentation mixture
means the mixture of juice and other ingredients in which the fermentation (from which the cider is obtained) takes place, as that mixture exists immediately before the fermentation process begins.
- pre-merger year
means the production year immediately preceding Year 1.
- pre-transfer period
means the period beginning with the commencement of the transfer period and ending with the day before the day on which the ownership interests were transferred.
- Production premises
means premises (whether or not in the United Kingdom) on which alcoholic products are produced.
- property, plant and equipment
has the meaning given, for the time being, by International Accounting Standard 16.
- proportional amortisation method
means a method of accounting under which—
- protected cell company
means a protected cell company incorporated under Part 4 of the Risk Transformation Regulations 2017 (S.I. 2017/1212);
- provisional bilateral safeguarding amount
means the additional amount of import duty mentioned in paragraph (11)(3)(a) of Schedule 5 as that provision applies by virtue of this Schedule;
- provisional suspension of tariff rate reduction
has the meaning given in paragraph (aa) of paragraph 11(3) of Schedule 5 (see paragraph 8(1)(a));
- Qualifying alternative finance arrangements
means arrangements— a that constitute alternative finance arrangements for the purposes of Chapter 6 of Part 6 of CTA 2009 (alternative finance arrangements), or b that do not constitute alternative finance arrangements only as a result of section 508 of that Act (exclusion provision not at arms length). 4 But arrangements that are analogous to a normal commercial loan are not qualifying alternative finance arrangements. 5 Arrangements are analogous to a normal commercial loan if, were the arrangements structured as a loan that resulted in the same or similar entitlements of the parties to the arrangements, they would constitute a normal commerci
- qualifying current tax expense
means the amount of the current tax expense as reflected in the member’s partially adjusted profits to the extent the expense relates to covered taxes.
- qualifying de-merger
means the separation of members of a relevant multinational group into two or more consolidated groups in an accounting period of the relevant multinational group, such that those members cease to all be consolidated by the same ultimate parent.
- qualifying dividend
means— (a) in the case of a qualifying dividend regime falling within paragraph (a) of the definition of qualifying dividend regime, a dividend or other distribution made to an owner of the entity, (b) in the case of a qualifying dividend regime falling within paragraph (b) of the definition of qualifying dividend regime, a dividend or other distribution which would count towards satisfying the condition that a sufficient proportion of the relevant profits of the UK REIT or overseas REIT equivalent have been distributed (assuming that condition had not already been met), or (c) in the case of a qualifying dividend regime falling within paragraph (c) of the definition of qualifying dividend regime, a patronage dividend;
- qualifying dividend regime
means a tax regime designed to result in a single level of taxation on the owners of an entity through— (a) a deduction from the income of the entity for distributions of profits to the owners, (b) a regime where certain of the profits (“the relevant profits”) of a UK REIT or overseas REIT equivalent are not taxed provided a sufficient proportion of the relevant profits is distributed, or (c) a regime applicable to a supply cooperative that exempts the cooperative from taxation on profits in connection with its distribution of patronage dividends;
- Qualifying draught products
means alcoholic products that—
- qualifying electricity purchase costs
means costs reasonably incurred in the purchase of electricity in order to comply with the terms of an agreement under which it was expected that a relevant generating station will generate but does not do so.
- qualifying flavourings
means any products falling within commodity code 3302 of the customs tariff established by regulations made under section 8 of TCTA 2018.
- qualifying food product
means—
- Qualifying fruit juice
means apple or pear juice of a gravity of at least 1033 degrees.
- qualifying income tax expense
means income tax expense adjusted to exclude—
- qualifying indirect activity
means an activity mentioned in paragraph 31 of the Guidelines on the Meaning of Research and Development for Tax Purposes issued on 7 March 2023 and as amended from time to time;
- Qualifying project
means a project to commission—
- qualifying system
means—
- qualifying taxes
means taxes accrued in the relevant period on actual or deemed distributions of profits;
- qualifying tier one capital
means an instrument issued by an entity pursuant to regulatory requirements applicable to the banking or insurance sector that is convertible to equity or written down if a pre-specified trigger event occurs and that has other features which are designed to aid loss absorbency in the event of a financial crisis.
- qualifying transformer vehicle
means— ((a)) a qualifying transformer vehicle within the meaning of the Risk Transformation (Tax) Regulations 2017 (S.I. 2017/1271), or ((b)) a part of a protected cell company that is a qualifying transformer vehicle within the meaning of those Regulations;
- quality
includes timing, nature and extent.
- Recorded
means values recorded for the purposes of preparing the consolidated financial statements of the ultimate parent (and not values as substituted as a result of any other provision of this Part).
- refundable tax credit
means a tax credit which— is payable in cash or cash equivalents (which for these purposes includes by way of discharge against a liability to a tax which is not a covered tax).
- registered group
means a multinational group that is registered under this paragraph.
- regulated aerodrome
has the meaning given by section 21(6A);”
- relevant accounting period of a company
means an accounting period in respect of which— i the company, together with one or more other enterprises, constitutes an MNE Group within the meaning of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 (S.I. 2016/237) (see regulation 2(3) of those Regulations), and ii the MNE Group meets the threshold requirement within the meaning of those Regulations (see regulations 3(2) to (4) of those Regulations);
- relevant alcoholic products
means alcoholic products which, if they had been produced in the United Kingdom, would have been charged with alcohol duty under this Partat a rate greater than nil.
- relevant date
means—
- relevant day
means—
- relevant dispensing instructions
means— a the instructions for use of the flavour concentrate provided with, or for the purposes of use with, the concentrate or a dispensing machine with which it is designed to be used;
- relevant options
has the meaning given in subsection (5)(b);
- relevant period
means a period in respect of which— i the partnership to which the partnership statement relates, together with one or more other enterprises, constitutes an MNE Group within the meaning of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 (S.I. 2016/237) (see regulation 2(3) of those Regulations), and ii the MNE Group meets the threshold requirement within the meaning of those Regulations (see regulations 3(2) to (4) of those Regulations);
- relevant person
has the meaning given in section 1126A(10).”
- relevant person in an MNE Group
means— i a company, ii a trustee of a trust, or iii a partner in a partnership, where that company, the trustees or the partnership, together with one or more other enterprises, constitutes an MNE Group.”
- relevant place
means a place in— (a) the United Kingdom, (b) the territorial sea of the United Kingdom, or (c) a Renewable Energy Zone within the meaning of Part 2 of the Energy Act 2004 (see section 84(4) of that Act);
- relevant pre-entry deferred tax asset
means a deferred tax asset that arises as described in section 185(7A), (7B) or (7C);
- relevant pre-entry deferred tax liability
means a deferred tax liability that arises as described in section 185(7B).
- relevant premises
means—
- relevant purposes
means the purposes of determining the club’s liability to any charge to tax, or eligibility for any tax relief, that is affected by the club’s status as a CASC.
- relevant requirement
means any of the requirements in paragraphs 5(1), 6(2) or (4) or 7(1) of Schedule 5 to ITEPA 2003;
- Relevant revaluation method gain or loss
means a gain or loss, before making any adjustment to reflect tax expense amounts, arising as a result of the use of an accounting method or practice that—
- Relevant share acquisition adjustment
means a purchase accounting adjustment to the consolidated financial statements of an ultimate parent of a multinational group arising as a result of an entity becoming a member of the group as a result of the acquisition of ownership interests in the entity by an existing member of the group.
- Relevant tax period
means a tax period— a in respect of which— i the person mentioned in sub-paragraph (4)(a), ii in the case mentioned in sub-paragraph (4)(b), the trustees of the trust concerned, or iii in the case mentioned in sub-paragraph (4)(c), the partnership to which the partnership return relates, together with one or more other enterprises, constitutes an MNE Group within the meaning of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 (S.I. 2016/237) (see regulation 2(3) of those Regulations), and b in respect of which the MNE Group meets the threshold requirement within the meaning of those Regulations (see regulations 3(2) to (4) of
- relevant time
means—
- relevant year of assessment
means a year of assessment in respect of which— i the trustees of the trust concerned, together with one or more other enterprises, constitutes an MNE Group within the meaning of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 (S.I. 2016/237) (see regulation 2(3) of those Regulations), and ii the MNE Group meets the threshold requirement within the meaning of those Regulations (see regulations 3(2) to (4) of those Regulations);
- return
means a self-assessment return (including as amended under paragraph 14).
- Ring-fenced body
has the same meaning as in section 142A of the Financial Services and Markets Act 2000.
- scheme end date
has the same meaning as in the lump sum exit scheme (see regulation 2(1) of that scheme).
- securitisation company
has the meaning it has in the Taxation of Securitisation Companies Regulations 2006 (see regulation 4).
- security
means— (a) shares in, or debentures of, a company, or (b) interests of a company that has no share capital that are possessed by members of the company. 138ZC 1 This section applies where section 138ZB would, but for an election under this section, apply in relation to the issue by a company of shares in or debentures of that company in exchange for, or in respect of, shares in or debentures of another company. 2 The person to whom the shares or debentures are issued may elect for section 135 or 136 not to apply to the issue, and accordingly— a the exchange or scheme of reconstruction in question will not be treated as a reorganisation within the meaning of section 126, and b sect
- Settlement agreement
means an agreement in writing between the appellant and an officer of Revenue and Customs that is—
- settlement code
means— (a) the Balancing and Settlement Code, or (b) the Trading and Settlement Code;
- sitting day
means a day on which the House of Commons is sitting (and a day is only a day on which the House of Commons is sitting if the House begins to sit on that day).
- sovereign wealth fund
means an entity which is a governmental entity for the purposes of this Part as a result of meeting the condition in section 234(1)(b)(ii).
- Sparkling cider
means cider which—
- special tax site
means an area for the time being designated under section 113 of FA 2021.”
- specified
means specified by or under the regulations).
- Specified date
means—
- specified devolved social security benefit
means a social security benefit which is—
- Spirits
means—
- stack
means a chain of entities through which G has an indirect ownership interest in H which is comprised of an entity (“J”) which has a direct ownership interest in H and—
- stand-alone lump sum
has the meaning given by paragraph (3) of article 25 of the Taxation of Pension Schemes (Transitional Provisions) Order 2006 (S.I. 2006/572);
- stapled structure
means an arrangement entered into by two or more ultimate parents of consolidated groups where the following conditions are met— (a) as a result of the arrangements, 50% or more of the ownership Interests in the ultimate parents of the consolidated groups— (a) are by reason of form of ownership, restrictions on transfer, or other terms or conditions combined with each other, and (b) cannot be transferred or traded independently;
- Still cider
means cider that is not sparkling cider.
- subsidiary
has the meaning given by international accounting standards.”