Council Directive (EU) 2025/872

means the section of the Top-up tax information return that contains general information on the MNE group as a whole, including its corporate structure and a high-level summary of the application of Directive (EU) 2022/2523, such section being consistent with Section 1 of the standard template for the Top-up tax information return;

means a Member State that has implemented either a qualified income inclusion rule (IIR) or a qualified undertaxed profit rule (UTPR), as defined in Article 3, points (18) and (43), respectively, of Directive (EU) 2022/2523, or both, for the given Reporting fiscal year;

means the sections of the Top-up tax information return that contain information on the detailed application of the qualified IIR, qualified UTPR and qualified domestic top-up tax in respect of each jurisdiction where the MNE group is operating, such sections being consistent with Sections 2 and 3 of the standard template for the Top-up tax information return;

means a Member State that has only implemented a qualified domestic top-up tax, as defined in Article 3, point (28), of Directive (EU) 2022/2523 for the given Reporting fiscal year;

means the fiscal year to which the Top-up tax information return relates.

means the information return filed by an ultimate parent entity, designated filing entity, designated local entity or constituent entity for which a standard template is set out in Section IV of this Annex;