The Member State of the ultimate parent entity of the MNE group should receive the full Top-up tax information return. The Implementing Member State should be provided with the General section of the Top-up tax information return, provided that there is a constituent entity of the MNE group located in its territory. The QDTT-only Member State, where constituent entities of the MNE group are located, should be provided with the relevant parts of the General section of the Top-up tax information return, although QDTT-only Member States should not send any information in respect of the Top-up tax information return by automatic exchange of information.
Text as published in the Official Journal, reproduced verbatim (including any typographical quirks of the source). For the authentic version, see EUR-Lex.
