111M Application of UTPR in jurisdiction of ultimate parent entity

(1) This subsection provides that, subject to subsections (2) and (3) and sections 111AZ and 111AL, where the ultimate parent entity of an MNE group is located in a third country jurisdiction that is a low-tax jurisdiction, a constituent entity of that MNE group that is located in the State shall be subject to the UTPR top-up tax. The UTPR top-up tax is calculated in accordance with section 111N.

(2) Subsection (1) shall not apply where the ultimate parent entity is subject to a qualified IIR in respect of itself and its low-taxed constituent entities located in that jurisdiction.

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

Relevant Date: Finance Act 2024