(1) Subject to subsection (3), a partially-owned parent entity located in the State that owns directly or indirectly an ownership interest in a low-taxed constituent entity at any time during a fiscal year shall be subject to a top-up tax (in this section referred to as 'IIR top-up tax') in respect of that low-taxed constituent entity for the fiscal year.
(2) Subject to subsection (3), where a partially-owned parent entity located in the State is a low-taxed constituent entity in a fiscal year, that partially-owned parent entity shall be subject to IIR top-up tax for the fiscal year in respect of itself.
(3) Subsections (1) and (2) shall not apply where the ownership interests of the partially-owned parent entity referred to in subsection (1) or (2), as the case may be, are wholly owned, directly or indirectly, by another partially-owned parent entity that is subject to a qualified IIR for that fiscal year.