No 39 of 1997, Section 111AE, Link Report

Links from Section 111AE
Act	Linked to	Context
Taxes Consolidation Act, 1997	sec0004.html	(10)(a) Subject to subsection (11), for the purposes of subsection (4) and notwithstanding section (4)(b)(i), a constituent entity that is the lessor of property, plant or equipment leased under an operating lease may calculate a tangible asset carve-out in respect of the leased property, plant or equipment in accordance with paragraph (b) where the property, plant or equipment is located in the same jurisdiction as the constituent entity.
Taxes Consolidation Act, 1997	sec0111AAAD.html	(b)Paragraph (a) shall not apply where a filing constituent entity elects, in accordance with section 111AAAD, not to apply the substance-based income exclusion for the fiscal year.
Taxes Consolidation Act, 1997	sec0111AQ.html	(c) Where the income of a permanent establishment was wholly or partially reduced pursuant to section 111S(1) or 111AQ(5) as the case may be, the eligible payroll costs and eligible tangible assets of such permanent establishment shall be reduced in the same proportion from the calculation of the substance-based income exclusion amount for a jurisdiction for a fiscal year under this section for the MNE group or large-scale domestic group.
Taxes Consolidation Act, 1997	sec0111AQ.html	(II) the flow-through entity if it is the ultimate parent entity, reduced in proportion to the income excluded from the calculation of the qualifying income of the flow-through entity pursuant to subsections (1) and (2) of section 111AQ, provided that the eligible employees and eligible tangible assets, as the case may be, are located in the jurisdiction of the flow-through entity.
Taxes Consolidation Act, 1997	sec0111AR.html	(12)(a) Where an adjustment to the computation of qualifying income or loss of a constituent entity for a fiscal year has been made in accordance with section 111AR, the payroll carve-out for that constituent entity shall be reduced by the amount calculated in accordance with the formula:
Taxes Consolidation Act, 1997	sec0111AR.html	B is the total qualifying income of the constituent entity excluded by section 111AR for the fiscal year, and
Taxes Consolidation Act, 1997	sec0111AR.html	(b) Where an adjustment to the computation of qualifying income or loss of a constituent entity for a fiscal year has been made in accordance with section 111AR then the tangible asset carve-out for that constituent entity shall be reduced by the amount calculated in accordance with the formula:
Taxes Consolidation Act, 1997	sec0111AR.html	B is the total qualifying income of the constituent entity excluded by section 111AR for the fiscal year, and
Taxes Consolidation Act, 1997	sec0111Q.html	(ii) attributable to income that is excluded in accordance with section 111Q.
Taxes Consolidation Act, 1997	sec0111Q.html	(II) the carrying value of tangible assets used to derive income that is excluded in accordance with section 111Q,
Taxes Consolidation Act, 1997	sec0111R.html	(6)(a) For the purpose of subsections (3) and (4), the eligible payroll costs and eligible tangible assets, as the case may be, of a constituent entity which is a permanent establishment, shall be those that are included in its separate financial accounts in accordance with section 111R(1), provided that the eligible payroll costs and eligible tangible assets, as the case may be, are located in the same jurisdiction as the permanent establishment.
Taxes Consolidation Act, 1997	sec0111S.html	(c) Where the income of a permanent establishment was wholly or partially reduced pursuant to section 111S(1) or 111AQ(5) as the case may be, the eligible payroll costs and eligible tangible assets of such permanent establishment shall be reduced in the same proportion from the calculation of the substance-based income exclusion amount for a jurisdiction for a fiscal year under this section for the MNE group or large-scale domestic group.
Taxes Consolidation Act, 1997	sec0111S.html	(I) the constituent entity-owners of the flow-through entity, in proportion to the amount allocated to them pursuant to section 111S(4), provided that the eligible employees and eligible tangible assets, as the case may be, are located in the jurisdiction of the constituent entity-owners, and
Links to Section 111AE (from within TaxSource Total)
Act	Linked from	Context
Taxes Consolidation Act, 1997	sec0111A.html	“substance-based income exclusion amount” shall be construed in accordance with section 111AE(2)(a);
Taxes Consolidation Act, 1997	sec0111AAAD.html	Section 111AE(2)(b)
Taxes Consolidation Act, 1997	sec0111AD.html	is the substance-based income exclusion amount for the jurisdiction for the fiscal year determined in accordance with section 111AE.
Taxes Consolidation Act, 1997	sec0111AF.html	an adjustment to covered taxes or qualifying income or loss results in the recalculation of the effective tax rate and top-up tax of the MNE group or large-scale domestic group for a jurisdiction for a prior fiscal year, the effective tax rate and top-up tax shall be recalculated in accordance with sections 111AC, 111AD and 111AE.
Taxes Consolidation Act, 1997	sec0111AJ.html	(c) subject to subsection (6), the MNE group reports profit or loss before income tax in that jurisdiction that is equal to or less than the substance-based income exclusion amount as calculated in accordance with section 111AE and 111AX (in this section referred to as the ‘routine profits test’) in respect of constituent entities that are both—
Taxes Consolidation Act, 1997	sec0111AM.html	(c) in an acquisition year, the calculation of the eligible payroll costs of the target entity pursuant to section 111AE shall take into account only the costs that are reflected in the consolidated financial statements of the ultimate parent entity;
Taxes Consolidation Act, 1997	sec0111AM.html	(d) the calculation of the carrying value of the eligible tangible assets of the target entity pursuant to section 111AE shall be adjusted, where applicable, in proportion to the period in which the target entity was a member of the MNE group or large-scale domestic group during the acquisition year.
Taxes Consolidation Act, 1997	sec0111AT.html	(c) The substance-based income exclusion amount of a relevant investment entity shall be determined in accordance with subsections (1) to (7) and (10) to (12) of section 111AE, taking into account only eligible tangible assets and eligible payroll costs of eligible employees of the relevant investment entity.
Taxes Consolidation Act, 1997	sec0111AX.html	(1) For the purpose of applying section 111AE(3), the value of 5 per cent shall be replaced, for each fiscal year beginning in the calendar year set out in column (1) of the Table to this subsection, with the values set out in the column (2) of that Table:
Taxes Consolidation Act, 1997	sec0111AX.html	(2) For the purpose of applying section 111AE(4), the value of 5 per cent, shall be replaced, for each fiscal year beginning in the calendar year set out in column (1) of the Table to this subsection, with the values set out in column (2) of that Table:
Taxes Consolidation Act, 1997	sec0111D.html	(c) Subject to paragraph (d), where the amount of covered taxes referred to in paragraph (a) is the same, or is zero, in both jurisdictions, then, the constituent entity shall be deemed to be located in the jurisdiction in which the greater substance-based income exclusion amount under section 111AE is calculated on an entity basis.