Article 5 Ultimate parent entity in the Union | Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (Pillar Two Directive) | Better Regulation

AI Summary of Article 5 Ultimate parent entity in the Union

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Version status: Entered into force | Document consolidation status: Updated to reflect all known changes

Version date: 23 December 2022 - onwards

Article 5 Ultimate parent entity in the Union

1. Member States shall ensure that an ultimate parent entity that is a constituent entity located in a Member State is subject to the top-up tax (the 'IIR top-up tax') for the fiscal year in respect of its low-taxed constituent entities that are located in another jurisdiction or that are stateless.

2. Member States shall ensure that, where a constituent entity that is the ultimate parent entity of an MNE group or of a large-scale domestic group is located in a Member State that is a low-tax jurisdiction, it is subject to the IIR top-up tax in respect of itself and of all low-taxed constituent entities of the group located in the same Member State for the fiscal year.

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