Taxes Consolidation Act 1997 section 111AAL

Section 111AAL allows constituent entities of a multinational enterprise (MNE) group that are liable to UTPR top-up tax to simplify their reporting obligations by electing to form a UTPR group and appointing a single group filer to submit one return and bear the tax liability on behalf of all members.

• All constituent entities of an MNE group that would otherwise be individually required to file a UTPR return may elect to form a UTPR group and appoint one member as the UTPR group filer to file a single return on behalf of all members before the specified return date.
• Where the UTPR group filer files the return on time, the other members are relieved of their individual filing obligations and are not chargeable to UTPR top-up tax for that fiscal year; instead, the group filer becomes chargeable to the full amount of UTPR top-up tax allocated to the State for all relevant members.
• Any payment made by a relevant UTPR member to the group filer, up to the amount of UTPR top-up tax that member would otherwise have owed individually, is disregarded for corporation tax purposes and is not treated as a distribution or a charge on income.
• A relevant UTPR member may withdraw from the group at any time, and once the withdrawal is submitted to Revenue, the group filing and payment provisions cease to apply for fiscal years whose specified return date falls after the withdrawal date.