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“specified return date” has the meaning assigned to it in section 111AAF.

(8) All relevant information concerning the application of the QDTT Safe Harbour shall be included in the top-up tax information return for the fiscal year in accordance with section 111AAI.

(2) Notwithstanding section 111AD(3), and subject to subsections (3) to (6) and subject to subsections (3) to (7), on the making of an election by a filing constituent entity in respect of a QDTT subgroup for a fiscal year, jurisdictional top-up tax in respect of the QDTT subgroup for the fiscal year concerned, other than such portion of the jurisdictional top-up tax as comprises additional top-up tax determined in accordance with section 111AF(1)(b), shall be deemed to be zero (in this section, referred to as the ‘QDTT Safe Harbour’) where the qualified domestic top-up tax implemented under the tax law of that jurisdiction is determined to have met the QDTT Safe Harbour standards under an OECD peer review process in respect of that fiscal year.

(2) Notwithstanding section 111AD(3), and subject to subsections (3) to (6) and subject to subsections (3) to (7), on the making of an election by a filing constituent entity in respect of a QDTT subgroup for a fiscal year, jurisdictional top-up tax in respect of the QDTT subgroup for the fiscal year concerned, other than such portion of the jurisdictional top-up tax as comprises additional top-up tax determined in accordance with section 111AF(1)(b), shall be deemed to be zero (in this section, referred to as the ‘QDTT Safe Harbour’) where the qualified domestic top-up tax implemented under the tax law of that jurisdiction is determined to have met the QDTT Safe Harbour standards under an OECD peer review process in respect of that fiscal year.

(7) The QDTT Safe Harbour for a jurisdiction shall not apply where the central, state or local government, or their administration or agencies that carry out government functions, of that jurisdiction provides the tax attributes that result in the deferred tax assets and liabilities described in section 111AW(5) and the jurisdiction does not exclude those tax attributes from the computations in determining the total deferred tax adjustment amount or the simplified covered taxes (within the meaning of section 111AJ) under the transitional CbCR safe harbour (within the said meaning) implemented under the laws of that jurisdiction, when calculating the domestic top-up tax implemented under the laws of that jurisdiction.

(7) The QDTT Safe Harbour for a jurisdiction shall not apply where the central, state or local government, or their administration or agencies that carry out government functions, of that jurisdiction provides the tax attributes that result in the deferred tax assets and liabilities described in section 111AW(5) and the jurisdiction does not exclude those tax attributes from the computations in determining the total deferred tax adjustment amount or the simplified covered taxes (within the meaning of section 111AJ) under the transitional CbCR safe harbour (within the said meaning) implemented under the laws of that jurisdiction, when calculating the domestic top-up tax implemented under the laws of that jurisdiction.

“QDTT Safe Harbour standards” means the standards referred to as ‘Standards for a QDMTT Safe Harbour’ set out in the document referred to in paragraph (e) of the definition, in section 111B, of ‘OECD Pillar Two guidance’;