111F Intermediate parent entity in the State

(1)(a)&(b) Subsection (1) provides that, subject to subsection (3), an intermediate parent entity located in the State whose ownership interests are owned directly or indirectly by an ultimate parent entity located in a jurisdiction that has not applied a qualified IIR to the ultimate parent entity, shall be subject to the IIR top-up tax in respect of any low-taxed constituent entity it holds an ownership interest in either directly or indirectly for the fiscal year.

(2) Where, subject to subsection (3), an intermediate 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.

(3)(a)&(b) Where the ultimate parent entity of the intermediate parent entity is subject to a qualified IIR, or another intermediate parent entity is subject to a qualified IIR and owns, directly or indirectly, a controlling interest in the intermediate parent entity the above subsections shall not apply.

Relevant Date: Finance Act 2024