Taxes Consolidation Act 1997 section 111AP

Multi-parented MNE and large-scale domestic groups

Section 111AP deals with multi-parented MNE groups and multi-parented large-scale domestic groups, setting out how the Pillar Two rules apply when two or more groups operate together under a stapled structure or dual-listed arrangement.

• Where two or more groups with separate parent companies enter into a stapled structure or dual-listed arrangement, their entities are treated as members of a single multi-parented group for the purposes of the top-up tax rules.
• A multi-parented group is an MNE group if it includes entities or permanent establishments in different jurisdictions, and a large-scale domestic group if all entities are in the same jurisdiction.
• The IIR top-up tax rules (sections 111E to 111J) and the UTPR top-up tax rules (sections 111L to 111N and section 111AZ) apply to the parent entities and constituent entities of the multi-parented group, with top-up tax allocated according to each entity's share.
• The ultimate parent entities of the multi-parented group must file a top-up tax information return covering all the groups in the arrangement, unless they appoint a designated filing entity to do so.

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