1. Irish Tax Law
  2. Legislation (IE)
  3. Acts
  4. 1997
Date-stamp loading
  1. Taxes Consolidation Act, 1997 (No. 39)
  2. Income Tax and Corporation Tax: The Main Provisions (ss. 32-531)
  3. 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)
  4. Chapter 2 IIR and UTPR (ss. 111E-111N)
  5. 111L. Application of UTPR across MNE group.
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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 18 December 2023 - onwards
    Version 1 of 1    

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.

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