111AAAC.  Transitional simplified jurisdictional reporting

(1) In this section ‘simplified jurisdictional reporting framework’ means the method of reporting for the purposes of the top-up tax information return, referred to as the simplified jurisdictional reporting framework, in the document referred to in paragraph (f) of the definition, in section 111B, of ‘OECD Pillar Two guidance’.

(2) Where, for a fiscal year beginning on or before 31 December 2028 and ending on or before 30 June 2030—

(a) all of the relevant QDTT members of an MNE group, large-scale domestic group or joint venture group, as the case may be, are members of a QDTT group for a fiscal year, and the QDTT group filer has prepared and delivered a QDTT return, in respect of all of the relevant QDTT members, for the fiscal year on or before the specified return date, or

(b) there is no more than one member of an MNE group or joint venture group, as the case may be, that is a qualifying entity for the fiscal year,

then, on the making of an election by a filing constituent entity for the fiscal year, the filing constituent entity shall complete, in accordance with the simplified jurisdictional reporting framework, the top-up tax information return for the fiscal year, in respect of—

(i) the relevant QDTT members of the MNE group, large-scale domestic group or joint venture group, as the case may be, where paragraph (a) applies, or

(ii) the member of the MNE group or joint venture group, as the case may be, where paragraph (b) applies.

(3) Where, for a fiscal year beginning on or before 31 December 2028 and ending on or before 30 June 2030—

(a) members of an MNE group or joint venture group, as the case may be, are located in a jurisdiction other than the State for a fiscal year (referred to in this subsection as the ‘other jurisdiction members’),

(b) either—

(i) no charge to IIR top-up tax or UTPR top-up tax arises under this Part in respect of the other jurisdiction members for the fiscal year, or

(ii) where such a charge does arise, there is no requirement for such an amount to be allocated on a constituent entity by constituent entity basis,

and

(c) under the tax law of all jurisdictions in which qualified domestic top-up tax, qualified UTPR or qualified IIR may arise in respect of the other jurisdiction members for the fiscal year, the filing constituent entity may complete, in accordance with the simplified jurisdictional reporting framework, the top-up tax information return for the fiscal year, in respect of the other jurisdiction members,

then, on the making of an election by a filing constituent entity located in the State for the fiscal year, the filing constituent entity shall complete, in accordance with the simplified jurisdictional reporting framework, the top-up tax information return for the fiscal year, in respect of the other jurisdiction members.

(4) Subsection (2) shall not apply in respect of an investment entity that is not an excluded entity, of an MNE group or large-scale domestic group.