For a fiscal year a "UTPR group" comprises all constituent entities of an MNE group that would, in the absence of subsection (2), be required under section 111AAK to prepare and deliver a UTPR return, where those entities have elected to be members and have appointed one member as the "UTPR group filer" to prepare and deliver the UTPR return on behalf of the relevant UTPR members by the specified return date.

If the UTPR group filer prepares and delivers the return on or before the specified return date, section 111AAK does not apply to the other relevant members, those members are not chargeable to UTPR top-up tax for the fiscal year, and the filer is chargeable to an amount equal to the UTPR top-up tax of the MNE group allocated to the State under section 111N(2). Payments by relevant members to the filer, up to the amount they would otherwise have been chargeable to, are not taken into account for corporation tax profits or losses and are not distributions or charges on income. A relevant member may withdraw its election; subsections (2) to (4) then do not apply to fiscal years whose specified return date occurs after the withdrawal is submitted to the Revenue Commissioners.