Links from Section 111AAL | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
(1) For the purposes of this Chapter, a ‘UTPR group’ for a fiscal year shall comprise all of the constituent entities of an MNE group that would, in the absence of subsection (2), be required, in accordance with section 111AAK, to prepare and deliver to the Revenue Commissioners a UTPR return for the fiscal year (in this Chapter referred to as the ‘relevant UTPR members’), where all such relevant UTPR members— |
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Taxes Consolidation Act, 1997 |
(a)section 111AAK shall not apply to the other relevant UTPR members other than the UTPR group filer (in this subsection referred to as ‘the other relevant UTPR members’) for the fiscal year, |
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Taxes Consolidation Act, 1997 |
(c) the UTPR group filer shall be chargeable to an amount of UTPR top-up tax in respect of all of the relevant UTPR members in respect of whom the return is prepared and delivered for the fiscal year and such an amount shall be equal to the UTPR top-up tax amount of the MNE group allocated to the State, as determined in accordance with section 111N(2). |
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Links to Section 111AAL (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
“UTPR group” shall be construed in accordance with section 111AAL; |
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Taxes Consolidation Act, 1997 |
“UTPR group filer” has the meaning assigned to it in section 111AAL; |
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Taxes Consolidation Act, 1997 |
(1) Subject to section 111AAL, where the ultimate parent entity of an MNE group is located in a Member State that has made an election pursuant to Article 50.1 of the Directive, a constituent entity of that MNE group that is located in the State shall be subject to a top-up tax (in this section referred to as ‘UTPR top-up tax’) for the fiscal years beginning on or after 31 December 2023 calculated in accordance with section 111N. |
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Taxes Consolidation Act, 1997 |
(1) Subject to subsection (2) and section 111AAL, where during a fiscal year— |
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Taxes Consolidation Act, 1997 |
(1) Subject to subsections (2) and (3) and sections 111AZ and 111AAL, where during a fiscal year, the ultimate parent entity of an MNE group is a low-taxed constituent entity that is not located in a Member State, a constituent entity of that MNE group that is located in the State shall be subject to a top-up tax (referred to in this section as ‘UTPR top-up tax’) calculated in accordance with section 111N. |