Part 35B of the Principal Act is amended -

(a) in section 835I(1), by the insertion of the following definitions:

"'amount of foreign qualified domestic top-up tax payable or borne by a controlled foreign company' means -

(a) an amount of foreign qualified domestic top-up tax that is payable or borne by the controlled foreign company, or

(b) where an amount of foreign qualified domestic top-up tax is payable or borne by an entity under the laws of the territory in which the controlled foreign company is located, for the purposes of the qualified domestic top-up tax laws of the territory, in respect of the aggregate profits of that controlled foreign company and one or more other entities, taken together as a single taxable entity, the amount of foreign qualified domestic top-up tax that is apportioned to the controlled foreign company on a just and reasonable basis;

'corresponding qualified domestic top-up tax' means an amount of qualified domestic top-up tax that would be payable or borne by the controlled foreign company, if the controlled foreign company was located in the State, in accordance with section 111D, and section 111AAO did not apply;

'fiscal year' has the meaning given to it in section 111A(1);

'foreign qualified domestic top-up tax' means a qualified domestic top-up tax arising under the laws of a territory, other than the State;

'qualified domestic top-up tax' has the meaning given to it in section 111A(1);",