| Links from Section 111D | ||
|---|---|---|
| Act | Linked to | Context |
|
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, |
|
|
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, |
|
|
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 |
|
|
Taxes Consolidation Act, 1997 |
(d)paragraph (d) of the definition in section 111A of ‘permanent establishment’, it shall be considered to be stateless. |
|
|
Taxes Consolidation Act, 1997 |
(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. |
|
| Links to Section 111D (from within TaxSource Total) | ||
| Act | Linked from | Context |
|
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; |
|
|
Taxes Consolidation Act, 1997 |
(1) An entity or permanent establishment shall be a qualifying entity for a fiscal year, or an accounting period where paragraph (c) applies, if it is located in the State in accordance with section 111D, or would be if it was a constituent entity, and it is— |
|
|
Taxes Consolidation Act, 1997 |
(ii) located in that jurisdiction in accordance with section 111D. |
|
|
Taxes Consolidation Act, 1997 |
“corresponding qualified domestic top-up tax” means an amount of qualified domestic top-up tax that would be payable or borne by the controlled foreign company, if the controlled foreign company was located in the State, in accordance with section 111D, and section 111AAO did not apply; |
|