| Links from Section 111M | ||
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| Act | Linked to | Context |
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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. |
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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. |
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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. |
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| Links to Section 111M (from within TaxSource Total) | ||
| Act | Linked from | Context |
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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 |
(2) Except for MNE groups to which section 111AZ(1) applies, sections 111L, 111M and 111N shall apply to fiscal years beginning on or after 31 December 2024. |
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Taxes Consolidation Act, 1997 |
(b) all information that is necessary for the application of section 111M, including— |
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Taxes Consolidation Act, 1997 |
(1)(a) |
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Taxes Consolidation Act, 1997 |
(c) Where all of the constituent entities of an MNE group located in the State (in this paragraph referred to as ‘the domestic constituent entities’) consent, the UTPR top-up tax amount of the MNE group arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be, may be allocated to the domestic constituent entities for a fiscal year in a manner agreed between all of the domestic constituent entities, provided that the full amount of the UTPR top-up tax amount of the MNE group arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be— |
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Taxes Consolidation Act, 1997 |
(c) Where all of the constituent entities of an MNE group located in the State (in this paragraph referred to as ‘the domestic constituent entities’) consent, the UTPR top-up tax amount of the MNE group arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be, may be allocated to the domestic constituent entities for a fiscal year in a manner agreed between all of the domestic constituent entities, provided that the full amount of the UTPR top-up tax amount of the MNE group arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be— |
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