(1) In this section 'simplified jurisdictional reporting framework' means the method of reporting for the purposes of the top-up tax information return, referred to as the simplified jurisdictional reporting framework, in the document referred to in paragraph (f) of the definition, in section 111B, of 'OECD Pillar Two guidance'.
(2) Where, for a fiscal year beginning on or before 31 December 2028 and ending on or before 30 June 2030 -
(a) all of the relevant QDTT members of an MNE group, large-scale domestic group or joint venture group, as the case may be, are members of a QDTT group for a fiscal year, and the QDTT group filer has prepared and delivered a QDTT return, in respect of all of the relevant QDTT members, for the fiscal year on or before the specified return date, or
(b) there is no more than one member of an MNE group or joint venture group, as the case may be, that is a qualifying entity for the fiscal year,
then, on the making of an election by a filing constituent entity
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