(1) In this section -
'corporate income tax rate' means the nominal rate of corporate income tax (including any sub-national corporate income taxes) generally imposed on income in a jurisdiction;
'transition period fiscal year' means a fiscal year not exceeding twelve months that begins on or before 31 December 2025 and ends before 31 December 2026.
(2) For the purposes of section 111N(3), on the making of an election by a filing constituent entity, the top-up tax calculated for each low-taxed constituent entity of an MNE group or member of a joint venture group located in the jurisdiction of the ultimate parent entity of the MNE group or joint venture group concerned shall, where that jurisdiction has a corporate income tax rate that is equal to, or greater than, 20 per cent, be zero for a transition period fiscal year.
(3) A filing constituent entity shall not make an election in accordance with -
(a) section 111AJ(2), and
(b) subsection (2),
…