For a fiscal year a "QDTT group" comprises either all constituent entities of an MNE group, all constituent entities of a large‑scale domestic group, or a joint venture and its joint venture affiliates, that would, in the absence of subsection (2), be required under section 111AAN to prepare and deliver a QDTT return. All relevant QDTT members must elect to be members and appoint one member as the QDTT group filer to prepare and deliver the QDTT return on their behalf on or before the specified return date for the fiscal year.

The QDTT group filer must prepare and deliver the QDTT return for all relevant QDTT members on or before the specified return date. Where this occurs, section 111AAN does not apply to the other relevant QDTT members for that fiscal year, those members are not chargeable to domestic top‑up tax for the year, and the QDTT group filer is chargeable to domestic top‑up tax equal to the jurisdictional top‑up tax for the QDTT group as determined under section 111AAD. A payment by a relevant QDTT member to the filer, not exceeding the amount the member would have been chargeable to, is not taken into account for corporation tax purposes and is not a distribution or a charge on income. A relevant QDTT 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.