Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

The UTPR comes in one year after the implementation of the income inclusion rules and then, because of this section, the transitional UTPR safe harbour allows for America to not come under that provision for another year.

I do not want to get sidetracked by that. We have discussed the safe harbour provision that is very much aimed at countries that have a tax rate above 20%, and it gives them an extra 12 months but there are a number of other safe harbour provisions in the legislation, which in particular allow for the qualified domestic minimum top-up tax, QDMTT, the transitional country-by-country reporting and UTPR. Are all of these permanent? The transitional one is obviously temporary; it is 12 months. What about the country-by-country reporting and particularly, the QDMTT safe harbour, which is how we are operating our top-up tax? Is that an indefinite position or does this have an end date?