1.  The legal framework implemented in the domestic law of a third country jurisdiction shall be considered as equivalent to a qualified income inclusion rule set out in Chapter II if it fulfils the following conditions:

(a) it enforces a set of rules in accordance with which the parent entity of an MNE group shall compute and collect its allocable share of top-up tax in respect of the low-taxed constituent entities of the MNE group;

(b) it establishes a minimum effective tax rate of at least 15% below which a constituent entity is considered as low-taxed;

(c) for the purpose of computing the minimum effective tax rate, it only allows the blending of income of entities located within the same jurisdiction; and

(d) it provides for relief for any top-up tax that was paid in a Member State in application of the income inclusion rule set out in this Directive.

2.  The third country jurisdictions that have implemented a legal framework in their domestic law, which can be considered equivalent to a qualified income inclusion rule in accordance with paragraph 1, are included in a list set out in the Annex.

3.  This list may be modified as a result of a subsequent assessment of the legal framework implemented by a third country jurisdiction in its domestic law. The assessment shall be carried out by the Commission and in conformity with the conditions laid down in paragraph 1. Following such assessment, the Commission is empowered to adopt delegated acts in accordance with Article 52 in order to amend the Annex.

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