Part 4A Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (ss. 111A-111AAAE)

Comparing proposed amendment...


	Chapter 1 Interpretation and general (Part 4A) (ss. 111A-111D)
In force	111A. Interpretation (Part 4A).
In force	111B. Principles for construing rules in accordance with OECD Pillar Two guidance.
In force	111C. Scope of Part 4A.
In force	111D. Location of constituent entity.
	Chapter 2 IIR and UTPR (ss. 111E-111N)
In force	111E. Ultimate parent entity in the State.
In force	111F. Intermediate parent entity in the State.
In force	111G. Intermediate parent entity located in the State and held by excluded ultimate parent entity.
In force	111H. Partially-owned parent entity in the State.
In force	111I. Allocation of top-up tax under IIR.
In force	111J. IIR offset mechanism.
In force	111K. Effect of qualified domestic top-up tax.
In force	111L. Application of UTPR across MNE group.
In force	111M. Application of UTPR in jurisdiction of ultimate parent entity.
In force	111N. Calculation and allocation of UTPR top-up tax amount.
	Chapter 3 Calculation of the qualifying income or loss (ss. 111O-111S)
In force	111O. Determination of qualifying income or loss.
In force	111P. Adjustments to determine qualifying income or loss.
In force	111Q. International shipping income exclusion.
In force	111R. Allocation of qualifying income or loss between main entity and permanent establishment.
In force	111S. Allocation of qualifying income or loss of flow-through entity.
	Chapter 4 Calculation of adjusted covered taxes (ss. 111T-111AB)
In force	111T. Covered taxes.
In force	111U. Adjusted covered taxes.
In force	111V. Meaning of marketable transferable tax credit.
In force	111W. Equity investment inclusion election and qualified flow-through tax benefits of qualified ownership interests.
In force	111X. Total deferred tax adjustment amount.
In force	111Y. Qualifying loss election.
In force	111Z. Specific allocation of covered taxes incurred by certain types of constituent entities.
In force	111AA. Rules required for blended CFC regime.
In force	111AB. Post-filing adjustments and tax rate changes.
	Chapter 5 Calculation of the effective tax rate and the top-up tax (ss. 111AC-111AK)
In force	111AC. Determination of effective tax rate.
In force	111AD. Calculation of top-up tax.
In force	111AE. Substance-based income exclusion.
In force	111AF. Additional top-up tax.
In force	111AG. De minimis exclusion.
In force	111AH. Minority owned constituent entities.
In force	111AI. Qualified domestic top-up tax safe harbour.
In force	111AJ. Transitional CbCR safe harbour.
In force	111AK. Transitional UTPR safe harbour.
	Chapter 6 Corporate restructuring and holding structures (ss. 111AL-111AP)
In force	111AL. Application of consolidated revenue threshold to group mergers and demergers.
In force	111AM. Constituent entities joining and leaving MNE group or large-scale domestic group.
In force	111AN. Transfer of assets and liabilities.
In force	111AO. Joint ventures.
In force	111AP. Multi-parented MNE and large-scale domestic groups.
	Chapter 7 Tax neutrality and distribution regimes (ss. 111AQ-111AV)
In force	111AQ. Ultimate parent entity that is a flow-through entity.
In force	111AR. Ultimate parent entity subject to a deductible dividend regime.
In force	111AS. Eligible distribution tax systems.
In force	111AT. Determination of effective tax rate and top-up tax of investment entity.
In force	111AU. Election to treat investment entity as tax transparent entity.
In force	111AV. Election to apply taxable distribution method.
	Chapter 8 Transition Rules (ss. 111AW-111AZ)
In force	111AW. Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition.
In force	111AX. Transitional relief for substance-based income exclusion.
In force	111AY. Initial phase of exclusion from IIR and UTPR of MNE groups and large-scale domestic groups.
In force	111AZ. Delayed application of IIR and UTPR by Member States.
	Chapter 9 Domestic Top-up Tax (ss. 111AAA-111AAE)
In force	111AAA. Interpretation (Chapter 9).
In force	111AAB. Qualifying entities.
In force	111AAC. Chargeable entities.
In force	111AAD. Determining top-up amounts of qualifying entity.
In force	111AAE. Scope of application of qualifying domestic top-up tax.
	Chapter 10 Administration (ss. 111AAF-111AAAD)
In force	111AAF. Interpretation (Chapter 10).
In force	111AAG. Care and management.
In force	111AAH. Obligation to register.
In force	111AAI. Top-up tax information return.
In force	111AAJ. IIR return and self-assessment.
In force	111AAK. UTPR return and self-assessment.
In force	111AAL. UTPR group.
In force	111AAM. UTPR group recovery.
In force	111AAN. QDTT return and self-assessment.
In force	111AAO. QDTT group.
In force	111AAP. QDTT group recovery.
In force	111AAQ. Expression of doubt.
In force	111AAR. Actions by person acting under authority.
In force	111AAS. Date for payment.
In force	111AAT. Assessments and enquiries.
In force	111AAU. Revenue assessment.
In force	111AAV. Notice of Revenue assessment.
In force	111AAW. Appeal to Appeal Commissioners.
In force	111AAX. Surcharge for late return.
In force	111AAY. Interest on overdue amounts.
In force	111AAZ. Obligation to keep certain records.
In force	111AAAA. Use of currency.
In force	111AAAB. Penalties.
In force	111AAAC. Transitional simplified jurisdictional reporting.
In force	111AAAD. Elections.
	Chapter 11 Application (s. 111AAAE)
In force	111AAAE. Application (Part 4A).

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Part 4A Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (ss. 111A-111AAAE)

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