Links from Section 835AAD | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(a) an excess of expenses of management referred to in section 83(3), or |
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Taxes Consolidation Act, 1997 |
(12) Subject to subsections (13), (14), (15) and (16), where subsection (11) applies, the amount of deemed borrowing cost of the relevant entity shall be treated for the purposes of subsection (3) of section 83, and any further application of that subsection, as if it has been disbursed as expenses of management for the first-mentioned accounting period. |
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Taxes Consolidation Act, 1997 |
(b) a deduction in respect of an amount which, pursuant to subsection (19), was treated as an amount of interest for which relief could not be given by virtue of section 291A(6)(a) for the purposes of section 291A(6)(b)(ii), |
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Taxes Consolidation Act, 1997 |
(b) a deduction in respect of an amount which, pursuant to subsection (19), was treated as an amount of interest for which relief could not be given by virtue of section 291A(6)(a) for the purposes of section 291A(6)(b)(ii), |
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Taxes Consolidation Act, 1997 |
(19) Notwithstanding anything in this section, no amount shall be deductible in respect of a deemed borrowing cost that arises from a disallowable amount which reduced an amount of interest equivalent deducted in connection with the provision of a specified intangible asset, by reference to which allowances referred to in section 291A(6) (a)(i) are made, and for the purposes of section 291A(6)(b)(ii) such amount shall, for the accounting period in which the disallowable amount arises, be treated as an amount of interest for which relief cannot be given by virtue of section 291A(6)(a). |
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Taxes Consolidation Act, 1997 |
(19) Notwithstanding anything in this section, no amount shall be deductible in respect of a deemed borrowing cost that arises from a disallowable amount which reduced an amount of interest equivalent deducted in connection with the provision of a specified intangible asset, by reference to which allowances referred to in section 291A(6) (a)(i) are made, and for the purposes of section 291A(6)(b)(ii) such amount shall, for the accounting period in which the disallowable amount arises, be treated as an amount of interest for which relief cannot be given by virtue of section 291A(6)(a). |
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Taxes Consolidation Act, 1997 |
(19) Notwithstanding anything in this section, no amount shall be deductible in respect of a deemed borrowing cost that arises from a disallowable amount which reduced an amount of interest equivalent deducted in connection with the provision of a specified intangible asset, by reference to which allowances referred to in section 291A(6) (a)(i) are made, and for the purposes of section 291A(6)(b)(ii) such amount shall, for the accounting period in which the disallowable amount arises, be treated as an amount of interest for which relief cannot be given by virtue of section 291A(6)(a). |
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Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(c) offsetting a lower amount of loss or excess against its income under section 396(1), 399(1) or 399(2) than would have been offset, |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(c) offsetting a lower amount of loss or excess against its income under section 396(1), 399(1) or 399(2) than would have been offset, |
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Taxes Consolidation Act, 1997 |
(c) offsetting a lower amount of loss or excess against its income under section 396(1), 399(1) or 399(2) than would have been offset, |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(b) where there is an insufficiency of such profits, to create a loss or excess in an accounting period subsequent to the first-mentioned accounting period and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to that loss. |
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Taxes Consolidation Act, 1997 |
(8) Subject to subsections (9), (10), (15) and (16), where subsection (7) applies, a relevant entity’s deemed borrowing cost shall be treated as a loss or excess incurred in the first-mentioned accounting period (to the extent such a loss or excess would have arisen but for this Part) and relief for that loss or excess shall be given in accordance with section 31, 396(1) or 399, as the case may be, and sections 397, 400 and 401 shall apply to the amount of deemed borrowing cost referred to in subsection (7) in the same manner as they apply to a loss. |
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Taxes Consolidation Act, 1997 |
(1) Where section 835AAC applies to a relevant entity for an accounting period (in this section referred to as the “first-mentioned accounting period”), the relevant entity may carry forward the disallowable amount to succeeding accounting periods in accordance with this section and any such amount carried forward shall be referred to in this section as a “deemed borrowing cost”. |
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Links to Section 835AAD (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(7A) The predecessor shall not be entitled to relief under section 835AAD or 835AAE and the successor shall be entitled to relief under
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Taxes Consolidation Act, 1997 |
(7A) The predecessor shall not be entitled to relief under section 835AAD or 835AAE and the successor shall be entitled to relief under
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Taxes Consolidation Act, 1997 |
(7A) The predecessor shall not be entitled to relief under section 835AAD or 835AAE and the successor shall be entitled to relief under
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Taxes Consolidation Act, 1997 |
(6) For the purposes of determining the amount of relief available for total spare capacity, after the making of a claim or claims
for relief under this section, or
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Taxes Consolidation Act, 1997 |
(7) Where an amount that is not deductible in respect of a deemed borrowing cost under section 835AAD(19) is deducted in a subsequent accounting period, having been treated as an amount of interest for which relief cannot be given by virtue of section 291A(6)(a) for the purposes of section 291A(6)(b)(ii), the amount of total spare capacity available for any subsequent claims or deductions shall be reduced by the amount so deducted. |
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Taxes Consolidation Act, 1997 |
(11) For the purposes of the application of section 835AAD or 835AAE to an interest group, a reference in the section concerned to a relevant entity shall be construed as a reference to a member of an interest group. |
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Taxes Consolidation Act, 1997 |
“deemed borrowing cost” has the meaning assigned to it by section 835AAD(1); |