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(i)section 111E(1), in respect of constituent entities located in the State, or

(ii)section 111E(2),

(i)section 111F(1), in respect of constituent entities located in the State, or

(ii)section 111F(2),

(2) Where the ultimate parent entity of an MNE group is located in a third country jurisdiction, the top-up tax due by a constituent entity located in the State in accordance with section 111N(1), shall be reduced to zero in the first 5 years of the initial phase of the international activity of that MNE group, notwithstanding the requirements laid down in Chapter 5.