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(1) Subject to section 111AAO, a qualifying entity within the meaning of paragraphs (a) and (b) of section 111AAB(1) shall be chargeable to domestic top-up tax in respect of a fiscal year.

(2) A qualifying entity within the meaning of section 111AAB(1)(c) shall be chargeable to domestic top-up tax in respect of an accounting period.

(1) Subject to section 111AAO, a qualifying entity within the meaning of paragraphs (a) and (b) of section 111AAB(1) shall be chargeable to domestic top-up tax in respect of a fiscal year.

(4)(a) Subject to paragraph (b), where a securitisation entity is a member of an MNE group or large-scale domestic group, then no domestic top-up tax shall be charged on that securitisation entity for a fiscal year and for the purposes of determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of that MNE group or large-scale domestic group for the fiscal year, section 111AD(5) shall apply as if the sum, if any, of the qualifying income of all the qualifying entities of that MNE group or largescale domestic group for a fiscal year located in the State excluded the qualifying income, if any, of the securitisation entity.

(c) Where paragraph (a) applies and the securitisation entity is a minority-owned constituent entity, within the meaning of section 111AH, then in determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of the MNE group or large-scale domestic group for the fiscal year, the top-up tax of the securitisation entity calculated in accordance with section 111AH for the fiscal year shall be allocated to the other qualifying entities, excluding securitisation entities, in accordance with the formula in section 111AD(5) where ‘JTUT’ is the top-up tax of the securitisation entity calculated in accordance with section 111AH.

(c) Where paragraph (a) applies and the securitisation entity is a minority-owned constituent entity, within the meaning of section 111AH, then in determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of the MNE group or large-scale domestic group for the fiscal year, the top-up tax of the securitisation entity calculated in accordance with section 111AH for the fiscal year shall be allocated to the other qualifying entities, excluding securitisation entities, in accordance with the formula in section 111AD(5) where ‘JTUT’ is the top-up tax of the securitisation entity calculated in accordance with section 111AH.

(c) Where paragraph (a) applies and the securitisation entity is a minority-owned constituent entity, within the meaning of section 111AH, then in determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of the MNE group or large-scale domestic group for the fiscal year, the top-up tax of the securitisation entity calculated in accordance with section 111AH for the fiscal year shall be allocated to the other qualifying entities, excluding securitisation entities, in accordance with the formula in section 111AD(5) where ‘JTUT’ is the top-up tax of the securitisation entity calculated in accordance with section 111AH.

(c) Where paragraph (a) applies and the securitisation entity is a minority-owned constituent entity, within the meaning of section 111AH, then in determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of the MNE group or large-scale domestic group for the fiscal year, the top-up tax of the securitisation entity calculated in accordance with section 111AH for the fiscal year shall be allocated to the other qualifying entities, excluding securitisation entities, in accordance with the formula in section 111AD(5) where ‘JTUT’ is the top-up tax of the securitisation entity calculated in accordance with section 111AH.