(1) The top-up tax due by -
(a) an ultimate parent entity located in the State in accordance with -
(i) section 111E(1), in respect of constituent entities located in the State, or
or
(b) an intermediate parent entity located in the State in accordance with -
(i) section 111F(1), in respect of constituent entities located in the State, or
when the ultimate parent entity is an excluded entity,
shall be reduced to zero where -
(I) the ultimate parent entity or the intermediate parent entity are a member of an MNE group, in the first 5 years of the initial phase of the international activity of the MNE group, notwithstanding the requirements laid down in Chapter 5, or
(II) the ultimate parent entity or the intermediate parent entity are a member of a large-scale domestic group, in the first 5 years, starting from the first day of the fiscal year in which the large-scale domestic group falls within the scope of this Part for the first time.
(2) W
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