2‑50 UTPR Top‑up Tax Amount—special rule2‑50 UTPR Top‑up Tax Amount—special rule for consolidated groups

2‑50 UTPR Top‑up Tax Amount—special rule for consolidated groups

(1) Subsection (2) applies if: (a) a Constituent Entity of an MNE Group is a subsidiary member of a consolidated group; and (b) the head company of the consolidated group is not any of the following: (i) an Excluded Entity; (ii) an Investment Entity; (iii) an Insurance Investment Entity; (iv) a Securitisation Entity for the Fiscal Year. (2) Despite section 2‑45, the Constituent Entity’s UTPR Top‑up Tax Amount for the Fiscal Year is taken to be reduced to zero. (3) Subsection (4) applies if the Constituent Entity is the head company of a consolidated group. (4) The amount of the Constituent Entity’s UTPR Top‑up Tax Amount for the Fiscal Year is taken to be increased by the amount of each reduction under subsection (2) of this section (if any) in respect of a subsidiary member of the consolidated group. (5) This section applies in relation to a MEC group in the same way in which it applies in relation to a consolidated group. (6) The following terms have the same meaning in this section as they do in the Income Tax Assessment Act 1997: (a) consolidated group; (b) head company; (c) MEC group; (d) subsidiary member.