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 8 Transition Rules (ss. 111AW-111AZ)
  5. 111AY. Initial phase of exclusion from IIR and UTPR of MNE groups and large-scale domestic groups.
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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    

111AY. Initial phase of exclusion from IIR and UTPR of MNE groups and large-scale domestic groups.

(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

(ii) section 111E(2),

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

(ii) section 111F(2),

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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