Taxes Consolidation Act 1997 section 111AAO

QDTT group

Section 111AAO allows entities within a multinational enterprise group, a large-scale domestic group, or a joint venture group that are subject to domestic top-up tax to elect to form a "QDTT group" and appoint a single group filer to prepare and deliver one consolidated QDTT return on behalf of all members.

• Entities subject to domestic top-up tax within an MNE group, large-scale domestic group, or joint venture group may elect to form a QDTT group and appoint one member as the QDTT group filer, who prepares and delivers a single QDTT return for all members by the specified return date.
• Where the group filer submits the return on time, the other members are relieved of the obligation to file individual QDTT returns and are not individually chargeable to domestic top-up tax; instead, the group filer is chargeable to the full jurisdictional top-up tax for all members.
• Payments made by a member to the group filer to cover that member's share of the tax (up to the amount the member would otherwise have owed) are ignored for corporation tax purposes and are not treated as distributions or charges on income.
• Any member may withdraw its election to be part of the QDTT group, and once a withdrawal is submitted to Revenue, the group filing and payment provisions cease to apply for fiscal years whose specified return date falls after the date of withdrawal.