111L. Application of UTPR across MNE group

(1) Subject to subsection (2) and section 111AAL, where during a fiscal year—

(a) the ultimate parent entity of an MNE group is located in a jurisdiction that does not apply a qualified IIR, or

(b) the ultimate parent entity of an MNE group is an excluded entity,

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.

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