(1) Where an entity fails to deliver a GloBE return on or before the specified return date, the amount of GloBE tax which would have been payable if such a return had been delivered on or before that date shall be increased by an amount (in this section referred to as the 'surcharge'), equal to the percentage, specified in column (2) of the Table to this section, opposite the timing of the delivery of the return relative to the specified return date, specified in column (1) of the Table.
(2) Where subsection (1) applies, the amount of the surcharge shall not exceed -
(a) €50,000, where the surcharge applicable is 5 per cent, or
(b) €200,000, where the surcharge applicable is 10 per cent.
(3) Interest is payable under section 111AAY on any surcharge as if the surcharge were GloBE tax, and the surcharge and any interest on that surcharge is chargeable and recoverable as if the surcharge and that interest were GloBE tax.
(4) For the purposes of subsection (1) -
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