111G Intermediate parent entity located in the State and held by an excluded ultimate parent entity

(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 that is an excluded entity, 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 for the fiscal year.

(2) Where, subject to subsection (3), an intermediate parent entity is itself a low-taxed constituent entity, it shall be subject to the IIR top-up tax in respect of itself.

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

Relevant Date: Finance Act 2024