Taxes Consolidation Act 1997 section 111AAE

Scope of application of qualifying domestic top-up tax

Section 111AAE sets out which qualifying entities fall within the scope of the qualifying domestic top-up tax rules in Chapter 9, and the fiscal years or accounting periods from which those rules apply.

• Chapter 9 (qualifying domestic top-up tax) applies to qualifying entities as defined in section 111AAB(1).
• Constituent entities of multinational or large-scale domestic groups (within the meaning of paragraphs (a) or (b) of section 111AAB(1)) are subject to the rules for fiscal years beginning on or after 31 December 2023.
• Joint ventures and joint venture affiliates (within the meaning of paragraph (c) of section 111AAB(1)) are subject to the rules for accounting periods beginning on or after 31 December 2023.
• The distinction between "fiscal years" and "accounting periods" reflects the different frameworks applicable to group constituent entities on the one hand and joint venture entities on the other.