Finance Act 2025

Amendments relating to group payments

41. (1) The Principal Act is amended—

(a) in section 410—

(i) in subsection (1)(a)—

(I) by the substitution of the following definition for the definition of “tax”:

“ ‘tax’, in relation to a relevant territory other than the State, means any tax imposed in the relevant territory which corresponds to corporation tax in the State;”,

and

(II) by the insertion of the following definition:

“ ‘relevant territory’ means—

(i) a relevant Member State,

(ii) not being a territory referred to in subparagraph (i), a territory with the government of which arrangements having the force of law by virtue of section 826(1) have been made, or

(iii) not being a territory referred to in subparagraph (i) or (ii), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826(1) will have the force of law;”,

(ii) in subsection (1)(b)—

(I) in subparagraph (i), by the substitution of “relevant territory” for “relevant Member State”, and

(II) by the substitution of the following subparagraph for subparagraph (ii):

“(ii) references to—

(I) a company resident in a relevant Member State shall be construed as references to a company which, by virtue of the law of a relevant Member State, is resident for the purposes of tax in such a relevant Member State, and

(II) a company resident in a relevant territory shall be construed as references to a company which, by virtue of the law of a relevant territory, is resident for the purposes of tax in such a relevant territory.”,

(iii) in subsection (3)(a), by the substitution of “relevant territory” for “relevant Member State”, and

(iv) in subsection (4)(a)(i), by the substitution of “relevant territory” for “relevant Member State”,

and

(b) in section 243(5)(c), by the substitution of “section 242A, 267I or 410(4)” for “section 242A or 267I”.

(2) Subsection (1) shall apply to payments to which section 410 of the Principal Act applies made on or after the date of the passing of this Act.