(1) Where a constituent entity, of an MNE group or large-scale domestic group, located in the State, is required -
(a) in accordance with section 111AAI(1), to prepare and deliver to the Revenue Commissioners a top-up tax information return in respect of the MNE group or large-scale domestic group for a fiscal year and -
(i) the constituent entity, or
(ii) where an entity has been appointed as a designated local entity, the designated local entity on behalf of the constituent entity,
fails to deliver a correct and complete top-up tax information return to the Revenue Commissioners on or before the specified return date, or
(b) in accordance with section 111AAI(2)(c), to prepare and deliver to the Revenue Commissioners a notification of filer on or before the specified return date and -
(i) the constituent entity, or
(ii) where an entity has been appointed as a designated local entity, the designated local entity on behalf of the constituent entity,
fails to deliver a notification of fi
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