On 12 December 2023, a notice from the European Commission was published in the Official Journal of the European Union on the election to delay the application of the income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) under Article 50 of Council Directive (EU) 2022/2523 of 14 December 2022.  Under Article 50, Member States in which no more than 12 ultimate pare…