1. The first Reporting fiscal year for which the information is to be communicated under Article 8ae is the first fiscal year beginning from 31 December 2023.

2. For the Member States that have elected not to apply the IIR and the UTPR pursuant to Article 50(1) of Directive (EU) 2022/2523, the first Reporting fiscal year for which the information is to be communicated under Article 8ae shall be the first fiscal year following the end of such election.

Notwithstanding the first subparagraph of this paragraph, for the Member States that have elected not to apply the IIR and the UTPR pursuant to Article 50(1) of Directive (EU) 2022/2523 and have elected to apply a qualified domestic top-up tax pursuant to Article 11(1) of that Directive, the first Reporting fiscal year for which the information is to be communicated under Article 8ae shall be the first fiscal year during which the qualified domestic top-up tax applies.

3. The competent authority of the Member State shall communicate the information under Article 8ae with respect to the first Reporting fiscal year no later than 6 months after the filing deadline.

4. In any case, Member States shall communicate the information under Article 8ae for the first time no earlier than 1 December 2026.