111L Application of UTPR across MNE group

(1)(a)&(b) Provides that, subject to subsection (2) and section 111AL (which provides for rules regarding a UTPR Group), a constituent entity of an MNE group that is located in the State shall be subject to the UTPR top-up tax where a qualified IIR is not applied to the MNE group either because the ultimate parent entity is located in a jurisdiction that does not apply a qualified IIR or the ultimate parent entity is an excluded entity. The UTPR top-up tax is calculated in accordance with section 111N.

(2) Subsection (1) shall not apply to a constituent entity that is an investment entity.

Relevant Date: Finance Act 2024