Links from Section 111A | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
“qualifying entity” shall be construed in accordance with section 111AAB; |
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Taxes Consolidation Act, 1997 |
“domestic top-up tax” means a tax arising pursuant to section 111AAC; |
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Taxes Consolidation Act, 1997 |
“designated filing entity” means the constituent entity, other than the ultimate parent entity, that has been appointed by the MNE group or large-scale domestic group to fulfil the filing obligations set out in section 111AAI on behalf of the MNE group or the large-scale domestic group; |
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Taxes Consolidation Act, 1997 |
“filing constituent entity” means an entity filing a top-up tax information return in accordance with section 111AAI; |
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Taxes Consolidation Act, 1997 |
“top-up tax” means the top-up tax calculated for a jurisdiction or a constituent entity pursuant to section 111AD; |
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Taxes Consolidation Act, 1997 |
“substance-based income exclusion amount” shall be construed in accordance with section 111AE(2)(a); |
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Taxes Consolidation Act, 1997 |
“joint venture”, “joint venture affiliate” and “joint venture group” have the meaning assigned to them, respectively, in section 111AO; |
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Taxes Consolidation Act, 1997 |
“UTPR top-up tax” means a tax arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be. |
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Taxes Consolidation Act, 1997 |
“consolidated revenue test” has the meaning assigned to it in section 111C; |
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Taxes Consolidation Act, 1997 |
but does not include an entity that is an excluded entity within the meaning of section 111C; |
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Taxes Consolidation Act, 1997 |
“excluded entities” has the meaning assigned to it in section 111C; |
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Taxes Consolidation Act, 1997 |
“stateless constituent entity” means a constituent entity to which subsection (3)(b), (4)(d) or (6)(d)(i) of section 111D applies; |
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Taxes Consolidation Act, 1997 |
“IIR top-up tax” means a tax arising pursuant to subsection (1) or (2) of section 111E, subsection (1) or (2) of section 111F, subsection (1) or (2) of section 111G or subsection (1) or (2) of section 111H, as the case may be; |
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Taxes Consolidation Act, 1997 |
“IIR top-up tax” means a tax arising pursuant to subsection (1) or (2) of section 111E, subsection (1) or (2) of section 111F, subsection (1) or (2) of section 111G or subsection (1) or (2) of section 111H, as the case may be; |
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Taxes Consolidation Act, 1997 |
“IIR top-up tax” means a tax arising pursuant to subsection (1) or (2) of section 111E, subsection (1) or (2) of section 111F, subsection (1) or (2) of section 111G or subsection (1) or (2) of section 111H, as the case may be; |
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Taxes Consolidation Act, 1997 |
“IIR top-up tax” means a tax arising pursuant to subsection (1) or (2) of section 111E, subsection (1) or (2) of section 111F, subsection (1) or (2) of section 111G or subsection (1) or (2) of section 111H, as the case may be; |
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Taxes Consolidation Act, 1997 |
“UTPR top-up tax” means a tax arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be. |
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Taxes Consolidation Act, 1997 |
“UTPR top-up tax” means a tax arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be. |
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Taxes Consolidation Act, 1997 |
“qualifying income or loss” has the meaning assigned to it in section 111O(1); |
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Taxes Consolidation Act, 1997 |
“covered taxes” has the meaning assigned to it in section 111T; |
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Taxes Consolidation Act, 1997 |
“adjusted covered taxes” has the meaning assigned to it in section 111U; |
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Taxes Consolidation Act, 1997 |
“marketable transferable tax credit” has the meaning assigned to it in section 111V; |
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Taxes Consolidation Act, 1997 |
“non-marketable transferable tax credit” has the meaning assigned to it in section 111V; |
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Links to Section 111A (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
“fiscal year” has the meaning given to it in section 111A(1); |
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Taxes Consolidation Act, 1997 |
“qualified domestic top-up tax” has the meaning given to it in section 111A(1); |
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Taxes Consolidation Act, 1997 |
(a) for any tax which is a qualified IIR (within the meaning of section 111A(1)), or |
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Taxes Consolidation Act, 1997 |
(b) for any tax which is a qualified UTPR (within the meaning of section 111A(1)). |
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Taxes Consolidation Act, 1997 |
(e) the definition of ‘chargeable period’ in section 865(1)(a) shall be construed as if “has the same meaning as ‘fiscal year’ in section 111A” were substituted for “has the meaning assigned to it by section 321”; |
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Taxes Consolidation Act, 1997 |
(a)paragraph (a) of the definition in section 111A of ‘permanent establishment’, it shall be deemed to be located in the jurisdiction where it is treated as a permanent establishment and liable to tax under a tax treaty, |
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Taxes Consolidation Act, 1997 |
(b)paragraph (b) of the definition in section 111A of ‘permanent establishment’, it shall be deemed to be located in the jurisdiction where it is subject to income taxation based on its business presence, |
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Taxes Consolidation Act, 1997 |
(c)paragraph (c) of the definition in section 111A of ‘permanent establishment’, it shall be deemed to be located in the jurisdiction where it is situated, or |
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Taxes Consolidation Act, 1997 |
(d)paragraph (d) of the definition in section 111A of ‘permanent establishment’, it shall be considered to be stateless. |
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Taxes Consolidation Act, 1997 |
(1)(a) Subject to subsection (2), where a constituent entity is a permanent establishment to which paragraph (a), (b) or (c) of the definition in section 111A(1) of permanent establishment applies, the financial accounting net income or loss of the permanent establishment shall be the net income or loss reflected in the separate financial accounts of that permanent establishment. |
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Taxes Consolidation Act, 1997 |
(2)(a) Where a constituent entity is a permanent establishment to which paragraph (a) or (b) of the definition in section 111A(1) of permanent establishment applies, its financial accounting net income or loss shall be adjusted to reflect only the amounts and items of income and expense that are attributable to it in accordance with the applicable tax treaty or domestic law of the jurisdiction where it is located, regardless of the amount of income subject to tax and the amount of tax-deductible expenses in that jurisdiction. |
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Taxes Consolidation Act, 1997 |
(b) Where a constituent entity is a permanent establishment to which paragraph (c) of the definition in section 111A(1) of permanent establishment applies, its financial accounting net income or loss shall be adjusted to reflect only the amounts and items of income and expense that are attributable to it in accordance with Article 7 of the OECD Model Tax Convention on Income and Capital. |
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Taxes Consolidation Act, 1997 |
(c) Where a constituent entity is a permanent establishment to which paragraph (d) of the definition in section 111A(1) of permanent establishment applies, its financial accounting net income or loss shall be calculated based on— |
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Taxes Consolidation Act, 1997 |
“fiscal year” has the meaning given to it in section 111A(1); |
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Taxes Consolidation Act, 1997 |
“qualified domestic top-up tax” has the meaning given to it in section 111A(1); |
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Taxes Consolidation Act, 1997 |
(a) a qualified IIR (within the meaning of section 111A(1)), or |
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Taxes Consolidation Act, 1997 |
(b) a qualified UTPR (within the meaning of section 111A(1)). |