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(i) the company is a 90 per cent subsidiary (within the meaning of section 9 (as modified by paragraph (b))) of the parent company,

(b) For the purposes of subparagraph (i) of paragraph (a), section 9 shall apply as if, in subsection (1)(c) of that section, ‘directly or indirectly’ were substituted for ‘directly’.

“controlling interest” has the meaning assigned to it by section 111A;

“chargeable period” has the meaning assigned to it by section 321;

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

“correlative adjustment” means an adjustment of profits under the terms of an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

“mutual agreement reached” means an agreement reached between the competent authority of the State and a competent authority of another jurisdiction in accordance with a mutual agreement procedure under an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

(I) a thing done pursuant to sections 864 and 865, or

(II) a thing required to be done pursuant to sections 864 and 865,

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(a) a thing done pursuant to sections 864 and 865, or

(b) a thing required to be done pursuant to sections 864 and 865,

(i)sections 864 and 865 shall apply on that basis,

that sections 864 and 865 shall apply on that basis, and

(a) a correlative adjustment in respect of which a determination has been made under section 864, or

(iii) is not a transferor company for the purposes of section 865(10), and

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

(I) a thing done pursuant to sections 864 and 865, or

(II) a thing required to be done pursuant to sections 864 and 865,

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(a) a thing done pursuant to sections 864 and 865, or

(b) a thing required to be done pursuant to sections 864 and 865,

(i)sections 864 and 865 shall apply on that basis,

that sections 864 and 865 shall apply on that basis, and