Taxes Consolidation Act 1997 section 111AAAE

Application (Part 4A)

Section 111AAAE sets out the commencement dates for the GloBE (Global Anti-Base Erosion) top-up tax rules contained in this Part of the Act.

• The GloBE rules generally apply to fiscal years beginning on or after 31 December 2023.
• Sections 111L, 111M and 111N, which deal with the UTPR (Undertaxed Profits Rule) top-up tax, apply to fiscal years beginning on or after 31 December 2024 — one year later than the general commencement date.
• The one-year delay for sections 111L, 111M and 111N does not apply to MNE groups covered by section 111AZ(1), which deals with delayed application of the IIR and UTPR by Member States.
• The commencement of the domestic top-up tax rules is subject to section 111AAE, which contains separate provisions governing when those rules take effect.