No 39 of 1997, Section 111AW, Link Report

Links from Section 111AW
Act	Linked to	Context
Taxes Consolidation Act, 1997	sec0111AC.html	(10) The sum of the total amount of deferred tax expense that is attributable to the reversal of deferred tax assets described in subsection (5) that a constituent entity, joint venture or joint venture affiliate may include when determining the effective tax rate for a jurisdiction in accordance with section 111AC and the calculation of simplified covered taxes under section 111AJ shall not exceed the maximum amount allowable under subsections (7) to (9) during the grace period.
Taxes Consolidation Act, 1997	sec0111AJ.html	(10) The sum of the total amount of deferred tax expense that is attributable to the reversal of deferred tax assets described in subsection (5) that a constituent entity, joint venture or joint venture affiliate may include when determining the effective tax rate for a jurisdiction in accordance with section 111AC and the calculation of simplified covered taxes under section 111AJ shall not exceed the maximum amount allowable under subsections (7) to (9) during the grace period.
Taxes Consolidation Act, 1997	sec0111X.html	(e)~~For the purposes~~ Except where the tax law or practice of a jurisdiction provides otherwise in respect of the order of offset of losses against a covered tax, for the purposes of determining the total deferred tax adjustment amount, as set out in section 111X, the reversal of a loss deferred tax asset, as set out in section 111X, shall first be attributable to a loss deferred tax asset which arose in the most recent fiscal year until the balance of the loss deferred tax asset is exhausted by such amounts, and then, if necessary, to a loss deferred tax asset which arose in the next most recent fiscal year until the balance of the loss deferred tax asset is exhausted by such amounts, and so on for preceding fiscal years.
Taxes Consolidation Act, 1997	sec0111X.html	(e)~~For the purposes~~ Except where the tax law or practice of a jurisdiction provides otherwise in respect of the order of offset of losses against a covered tax, for the purposes of determining the total deferred tax adjustment amount, as set out in section 111X, the reversal of a loss deferred tax asset, as set out in section 111X, shall first be attributable to a loss deferred tax asset which arose in the most recent fiscal year until the balance of the loss deferred tax asset is exhausted by such amounts, and then, if necessary, to a loss deferred tax asset which arose in the next most recent fiscal year until the balance of the loss deferred tax asset is exhausted by such amounts, and so on for preceding fiscal years.
Taxes Consolidation Act, 1997	sec0111X.html	(f) For the purposes of determining the total deferred tax adjustment amount, as set out in section 111X, where a loss deferred tax asset arising in a fiscal year (in this paragraph referred to as the ‘originating fiscal year’) is attributable to both a qualifying loss and a loss that is not a qualifying loss, then, the reversal of that loss deferred tax asset, as set out in section 111X, shall be attributable to a qualifying loss in the same proportion as the qualifying loss bears to the sum of the qualifying loss and the loss that is not a qualifying loss in the originating fiscal year.
Taxes Consolidation Act, 1997	sec0111X.html	(f) For the purposes of determining the total deferred tax adjustment amount, as set out in section 111X, where a loss deferred tax asset arising in a fiscal year (in this paragraph referred to as the ‘originating fiscal year’) is attributable to both a qualifying loss and a loss that is not a qualifying loss, then, the reversal of that loss deferred tax asset, as set out in section 111X, shall be attributable to a qualifying loss in the same proportion as the qualifying loss bears to the sum of the qualifying loss and the loss that is not a qualifying loss in the originating fiscal year.
Links to Section 111AW (from within TaxSource Total)
Act	Linked from	Context
Taxes Consolidation Act, 1997	sec0111AAD.html	(5)(a) For the purposes of this subsection, ‘new transition year’ means the first fiscal year that a qualifying entity is subject to a qualified IIR or a qualified UTPR in a jurisdiction, where that fiscal year begins on a date later than the beginning of the transition year within the meaning of section 111AW(1).
Taxes Consolidation Act, 1997	sec0111AAD.html	(v) the deferred tax assets and deferred tax liabilities taken into account in determining the effective tax rate for a jurisdiction in accordance with section 111AW(2) shall be eliminated and that subsection shall be applied at the beginning of the new transition year;
Taxes Consolidation Act, 1997	sec0111AAD.html	(vi)section 111AW(3) shall apply to transactions occurring after 30 November 2021 and before the beginning of the new transition year but where domestic top-up tax was payable due to the application of section 111U(6) in respect of a deferred tax asset attributable to a tax loss, such deferred tax asset shall not be treated as arising from items excluded from the calculation of qualifying income or loss under Chapter 3.
Taxes Consolidation Act, 1997	sec0111AI.html	(7) The QDTT Safe Harbour for a jurisdiction shall not apply where the central, state or local government, or their administration or agencies that carry out government functions, of that jurisdiction provides the tax attributes that result in the deferred tax assets and liabilities described in section 111AW(5) and the jurisdiction does not exclude those tax attributes from the computations in determining the total deferred tax adjustment amount or the simplified covered taxes (within the meaning of section 111AJ) under the transitional CbCR safe harbour (within the said meaning) implemented under the laws of that jurisdiction, when calculating the domestic top-up tax implemented under the laws of that jurisdiction.
Taxes Consolidation Act, 1997	sec0111AJ.html	(c) deferred tax expense attributable to a deferred tax asset or deferred tax liability set out in subsection (5) of section 111AW, or the reversal thereof, in excess of the maximum amount allowed under subsections (7) to (10) of section 111AW.
Taxes Consolidation Act, 1997	sec0111AJ.html	(c) deferred tax expense attributable to a deferred tax asset or deferred tax liability set out in subsection (5) of section 111AW, or the reversal thereof, in excess of the maximum amount allowed under subsections (7) to (10) of section 111AW.
Taxes Consolidation Act, 1997	sec0111AJ.html	(a) the transition year referred to in section 111AW(2) for an MNE group in respect of a jurisdiction shall be the first fiscal year where the transitional CbCR safe harbour no longer applies to that MNE group in respect of that jurisdiction,
Taxes Consolidation Act, 1997	sec0111AJ.html	(b)section 111AW(3) shall continue to apply to a constituent entity, joint venture or joint venture affiliates, as the case may be, of an MNE group located in that jurisdiction for that fiscal year, and
Taxes Consolidation Act, 1997	sec0111AJ.html	(c) the transition year referred to in section 111AW(4) for a transferring entity shall be the first fiscal year where the transitional CbCR safe harbour no longer applies to that transferring entity.
Taxes Consolidation Act, 1997	sec0111O.html	(1) Subject to subsection (2), ‘qualifying income or loss’, in respect of a fiscal year, means the financial accounting net income or loss of a constituent entity for a fiscal year, as adjusted in accordance with sections 111P, 111Q, 111R, 111S, 111W, 111AB, 111AM, 111AN, 111AQ, 111AR, 111AV and 111AW.
Taxes Consolidation Act, 1997	sec0111X.html	(c)Subsection (5)(a) and section 111AW(2) shall apply to the substitute loss carry-forward deferred tax asset.
Taxes Consolidation Act, 1997	sec0111Y.html	(b) the deferred tax assets and deferred tax liabilities for the jurisdiction, if any, shall be taken into account as if they had been calculated in accordance with section 111X and 111AW for the prior fiscal year.