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(2) Except for MNE groups to which section 111AZ(1) applies, sections 111L, 111M and 111N shall apply to fiscal years beginning on or after 31 December 2024.

(iii) all information necessary for the allocation of that top-up tax based on the UTPR allocation formula set out in section 111N;

(c) the UTPR group filer shall be chargeable to an amount of UTPR top-up tax in respect of all of the relevant UTPR members in respect of whom the return is prepared and delivered for the fiscal year and such an amount shall be equal to the UTPR top-up tax amount of the MNE group allocated to the State, as determined in accordance with section 111N(2).

(2) For the purposes of section 111N(3), on the making of an election by a filing constituent entity, the top-up tax calculated for each low-taxed constituent entity of an MNE group or member of a joint venture group located in the jurisdiction of the ultimate parent entity of the MNE group or joint venture group concerned shall, where that jurisdiction has a corporate income tax rate that is equal to, or greater than, 20 per cent, be zero for a transition period fiscal year.

(5) The top-up tax of a joint venture group for a fiscal year shall be reduced by each parent entity’s allocable share of the top-up tax under subsection (3) of each member of the joint venture group that is brought into charge under subsection (4) and any remaining amount of top-up tax shall be added to the total UTPR top-up tax amount pursuant to section 111N(3).

(6)Sections 111L to 111N and section 111AZ shall apply to constituent entities of a multi-parented MNE group or multi-parented large-scale domestic group, as the case may be, taking into account the top-up tax of each low-taxed constituent entity that is a member of the multi-parented MNE group or multi-parented large-scale domestic group.

(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.

(1) Subject to section 111AAL, where the ultimate parent entity of an MNE group is located in a Member State that has made an election pursuant to Article 50.1 of the Directive, a constituent entity of that MNE group that is located in the State shall be subject to a top-up tax (in this section referred to as ‘UTPR top-up tax’) for the fiscal years beginning on or after 31 December 2023 calculated in accordance with section 111N.

a constituent entity of that MNE group that is located in the State shall be subject to a top-up tax (referred to in this section as ‘UTPR top-up tax’) calculated in accordance with section 111N.

(1) Subject to subsections (2) and (3) and sections 111AZ and 111AAL, where during a fiscal year, the ultimate parent entity of an MNE group is a low-taxed constituent entity that is not located in a Member State, a constituent entity of that MNE group that is located in the State shall be subject to a top-up tax (referred to in this section as ‘UTPR top-up tax’) calculated in accordance with section 111N.