The Undertaxed Payments rule (UTPR) has the same general purpose as the income inclusion rule (IIR). More specifically, the policy rationale of the UTPR is to protect jurisdictions against base erosion through intra-group payments to low-taxed entities while ensuring that, in aggregate, the application of the GloBE rules does not result in the MNE Group being subject to tax on its income in those jurisdictions where it operates in excess of the minimum rate. While the IIR and the UTPR have the same general purpose they have a different function and operate in a very different way. The IIR provides for a mechanism to collect the top-up tax based on a Parent’s The definition of Parent is set out in Section 6.2 and may include a Partially Owned Intermediate Parent. direct or indirect ownership of the low-tax Constituent Entities. The UTPR serves, in part, as a backstop to the IIR and reduces the incentives for tax driven inversions by providing a mechanism for making an adjustment in respect of any remaining top-up tax in relation to profits of a Constituent Entity that is not in scope of an applicable IIR. The UTPR also has the purpose of addressing base erosion through deductible intra-group payments. By operating as a backstop and targeting base eroding payments the UTPR serves a hybrid purpose and different aspects of the rules in this chapter may serve one or the other purpose, depending on the situation. The UTPR operates through an allocation key that is based on, and therefore limited in its application to the extent of, intra-group payments.