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

I move amendment No. 83:

In page 225, to delete lines 10 to 13 and substitute the following:

“(4)Section 111AY shall apply for domestic purposes—

(a)where none of the ownership interests in a qualifying entity are held by a parent entity subject to a qualified IIR, and

(b)as if the following were substituted for subsection (1) of that section—

‘(1)The domestic top-up tax due by a qualifying entity in accordance with section 111AAC (1) shall be reduced to zero where—

(a) the qualifying entity is a member of an MNE group, in the first 5 years of the initial phase of the international activity of the MNE group, starting from the first day of the fiscal year in which the MNE group falls within the scope of this Part for the first time, notwithstanding the requirements laid down in Chapter 5,

(b) the qualifying entity is a member of a large-scale domestic group, in the first 5 years, starting from the first day of the fiscal year in which the large-scale domestic group falls within the scope of this Part for the first time, or(c)the qualifying entity is an entity within the meaning of section 111AAB(1)

(c), in the first 5 years, starting from the first day of the accounting period in which entity falls within the scope of this Part for the first time.’.”.