Revenue Note for Guidance

The content shown on this page is a Note for Guidance produced by the Irish Revenue Commissioners. To view the section of legislation to which the Note for Guidance applies, click the link below:

Revenue Note for Guidance

CHAPTER 2

IIR and UTPR

Overview

Chapter 2 of Part 4A sets out the general charging provisions for the IIR and the UTPR. The IIR imposes a top-up tax on a parent entity with respect to low taxed constituent entities subject to an effective tax rate below the Minimum Rate. The UTPR serves as a backstop to the IIR. To the extent that a low taxed constituent entity is not subject to a tax under an IIR, the UTPR operates to collect the top-up tax due (with credit given for QDTT where appropriate).

111E Ultimate parent entity in the State

(1)(a)&(b) The section provides that an ultimate parent entity that is a constituent entity located in the State shall be subject to a top-up tax in respect of any low-taxed constituent entity it holds an ownership interest in either directly or indirectly.

(2) Where an ultimate parent entity located in the State is itself a low-taxed constituent entity, it shall be subject to the IIR top-up tax in respect of itself.

Relevant Date: Finance Act 2024