Link Report

(a) the consolidated financial statements are consolidated financial statements to which paragraph (a) or (c), as the case may be, of the definition of that term in section 111A(1) applies,

(10) The elections referred to in subsections (2) and (7) shall be made in accordance with section 111AAAD.

(9) All relevant information concerning the application of the simplified calculations safe harbour shall be included in the top-up tax information return for the fiscal year in accordance with section 111AAI.

(6) The requirements of this subsection shall be met where the effective tax rate of a jurisdiction for a fiscal year calculated in accordance with section 111AC is equal to or greater than the minimum tax rate.

(2) Subject to subsection (3), notwithstanding section 111AD(3), at the election of the filing constituent entity, the jurisdictional top-up tax for a jurisdiction for a fiscal year, other than additional top-up tax for a jurisdiction for a fiscal year determined in accordance with section 111AF, shall be deemed to be zero where the MNE group or large-scale domestic group, as the case may be, meet the requirements set out in subsection (4), (5) or (6).

(4) The requirements of this subsection shall be met where there is no excess profit determined for a jurisdiction for a fiscal year in accordance with section 111AD(4).

(2) Subject to subsection (3), notwithstanding section 111AD(3), at the election of the filing constituent entity, the jurisdictional top-up tax for a jurisdiction for a fiscal year, other than additional top-up tax for a jurisdiction for a fiscal year determined in accordance with section 111AF, shall be deemed to be zero where the MNE group or large-scale domestic group, as the case may be, meet the requirements set out in subsection (4), (5) or (6).

where the average qualifying revenue and average qualifying income or loss of all constituent entities of an MNE group or large-scale domestic group are determined in accordance with section 111AG.

(7) Notwithstanding sections 111O(1), 111U and 111AG(3), for the purposes of this section, a filing constituent entity may make an election to determine the qualifying income or loss, qualifying revenue and adjusted covered taxes of an NMCE for a fiscal year using the NMCE simplified calculations.

“CbC report” has the same meaning as in section 111AJ(1);

“OECD Report of 2015” and “OECD CBCR Guidance” have the meaning assigned to them, respectively, in section 111AJ(1);

(7) Notwithstanding sections 111O(1), 111U and 111AG(3), for the purposes of this section, a filing constituent entity may make an election to determine the qualifying income or loss, qualifying revenue and adjusted covered taxes of an NMCE for a fiscal year using the NMCE simplified calculations.

(7) Notwithstanding sections 111O(1), 111U and 111AG(3), for the purposes of this section, a filing constituent entity may make an election to determine the qualifying income or loss, qualifying revenue and adjusted covered taxes of an NMCE for a fiscal year using the NMCE simplified calculations.