Links from Section 111Z | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
(8) Where the qualifying income of a permanent establishment is treated as qualifying income of the main entity in accordance with section 111R(4), any covered taxes arising in the jurisdiction where the permanent establishment is located and associated with such income, shall be treated as covered taxes of the main entity for an amount not exceeding— |
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Taxes Consolidation Act, 1997 |
is the amount of qualifying income of the permanent establishment which is treated as qualifying income of the main entity in accordance with section 111R(4), and |
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Taxes Consolidation Act, 1997 |
(3) A constituent entity-owner shall be allocated the amount of any covered taxes that are included in the financial accounts of a tax transparent entity and that relate to qualifying income or loss allocated to a constituent entity-owner in accordance with section 111S(4). |
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Links to Section 111Z (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(2) For fiscal years that begin on or before 31 December 2025 but not including a fiscal year that ends after 30 June 2027, for the purposes of section 111Z(4), allocable blended CFC tax shall be allocated from a constituent entity-owner to a constituent entity in accordance with the following formula: |
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Taxes Consolidation Act, 1997 |
(f)subsections (4), (5) and (7) of section 111Z did not apply, |
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Taxes Consolidation Act, 1997 |
(g) any covered tax of a main entity that is allocable to a permanent establishment located in the State under subsection (2) of 111Z was not allocated to that permanent establishment, |
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Taxes Consolidation Act, 1997 |
(h) a reference to covered taxes in section 111Z(6) is construed as only including withholding taxes imposed on the distribution of a qualifying entity in the State, |
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Taxes Consolidation Act, 1997 |
(iii)section 111Z; |