Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

On the QDMTT data, and please correct me if I am wrong, if there is a subsidiary in Ireland, which is taxed at 12.5%, then according to Revenue its effective tax rate is about 11.8% or something in that region so it must be increased to 15%. QDMTT will apply and increase the percentage by 3% so there will be a sum of money that that subsidiary will have to pay to reach the minimum effective tax rate of 15%. What if that same subsidiary's parent company is in a jurisdiction that is outside of pillar 2 and, therefore, the undertaxed profits rule will kick in? Let us say a company must pay €100 million to satisfy the 15% minimum effective tax rate. Is it above that the money that a company would get from the UTPR cannot be used to bring up its effective tax rates? Would there be a separate filing as the UTPR would be clearly identified and separate from the top-up tax?