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(iv)section 111AA;

(a) the qualifying entity is an entity within the meaning of section 111AAB(1)(c), or

(3) For the purposes of subsection (1), this Part has effect for domestic purposes in respect of a qualifying entity within the meaning of section 111AAB(1)(c) as if—

(c) the qualifying entity is an entity within the meaning of section 111AAB(1)(c), in the first 5 years, starting from the first day of the accounting period in which entity falls within the scope of this Part for the first time.’.

‘(1) The domestic top-up tax due by a qualifying entity in accordance with section 111AAC(1) shall be reduced to zero where—

(b) the formula in section 111AD(3) took no account of qualified domestic top-up tax payable,

(v)section 111AH;

(i)subsections (3) and (5) of section 111AO did not apply, and

(vi)section 111AO;

(j)subsections (5) to (7) of section 111AP did not apply.

(vii)section 111AP;

(viii)section 111AQ;

(ix)section 111AR;

(c)sections 111T(1)(b) and 111AS were omitted,

(x)section 111AU;

(xi)section 111AV.

(5)(a) For the purposes of this subsection, ‘new transition year’ means the first fiscal year that a qualifying entity is subject to a qualified IIR or a qualified UTPR in a jurisdiction, where that fiscal year begins on a date later than the beginning of the transition year within the meaning of section 111AW(1).

(v) the deferred tax assets and deferred tax liabilities taken into account in determining the effective tax rate for a jurisdiction in accordance with section 111AW(2) shall be eliminated and that subsection shall be applied at the beginning of the new transition year;

(vi)section 111AW(3) shall apply to transactions occurring after 30 November 2021 and before the beginning of the new transition year but where domestic top-up tax was payable due to the application of section 111U(6) in respect of a deferred tax asset attributable to a tax loss, such deferred tax asset shall not be treated as arising from items excluded from the calculation of qualifying income or loss under Chapter 3.

(4)Section 111AY shall apply for domestic purposes—

(e) there were inserted in section 111O the following subsections after subsection (3):

(i)section 111R;

(ii)section 111S;

(c)sections 111T(1)(b) and 111AS were omitted,

(vi)section 111AW(3) shall apply to transactions occurring after 30 November 2021 and before the beginning of the new transition year but where domestic top-up tax was payable due to the application of section 111U(6) in respect of a deferred tax asset attributable to a tax loss, such deferred tax asset shall not be treated as arising from items excluded from the calculation of qualifying income or loss under Chapter 3.

(ii)section 111X(9) shall not apply to any deferred tax liability that was taken into account in calculating the effective tax rate for the purposes of determining the domestic top-up tax of the qualifying entity for a fiscal year prior to the new transition year, that was not recaptured prior to the new transition year;

(iii)section 111X(9) shall apply to deferred tax liabilities that are taken into account in, and subsequent to, the new transition year;

(iv) any qualifying loss deferred tax asset in respect of a fiscal year preceding the new transition year shall be eliminated and the filing constituent entity may make a new election in accordance with section 111Y(1)(a) and, notwithstanding section 111Y(5), the filing constituent entity may make a new election in the top-up tax information return of the MNE group for the new transition year in accordance with section 111Y(1)(a);

(iv) any qualifying loss deferred tax asset in respect of a fiscal year preceding the new transition year shall be eliminated and the filing constituent entity may make a new election in accordance with section 111Y(1)(a) and, notwithstanding section 111Y(5), the filing constituent entity may make a new election in the top-up tax information return of the MNE group for the new transition year in accordance with section 111Y(1)(a);

(iv) any qualifying loss deferred tax asset in respect of a fiscal year preceding the new transition year shall be eliminated and the filing constituent entity may make a new election in accordance with section 111Y(1)(a) and, notwithstanding section 111Y(5), the filing constituent entity may make a new election in the top-up tax information return of the MNE group for the new transition year in accordance with section 111Y(1)(a);

(f)subsections (4), (5) and (7) of section 111Z did not apply,

(g) any covered tax of a main entity that is allocable to a permanent establishment located in the State under subsection (2) of 111Z was not allocated to that permanent establishment,

(h) a reference to covered taxes in section 111Z(6) is construed as only including withholding taxes imposed on the distribution of a qualifying entity in the State,

(iii)section 111Z;