(1) For the purpose of this section, 'transition year', for a jurisdiction, means the first fiscal year in which an MNE group or large-scale domestic group falls within the scope of a qualified IIR, qualified UTPR or qualified domestic top-up tax, in respect of that jurisdiction.
(a) When determining the effective tax rate for a jurisdiction in accordance with section 111AC -
(i) in a transition year, and
(ii) for each subsequent fiscal year,
the MNE group or a large-scale domestic group shall take into account all the deferred tax assets and deferred tax liabilities, reflected or disclosed in the financial accounts of all the constituent entities in a jurisdiction for the transition year.
(b) For the purposes of paragraph (a), deferred tax assets and deferred tax liabilities shall be taken into account at the lower of -
(i) the minimum tax rate, or
(ii) the applicable domestic tax rate.
(c) Notwithstanding paragraph (b), where a deferred tax asset -
(i) is attributable to a qualif
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