111H Partially-owned parent entity in the State

(1) Subsection (1) provides that, subject to subsection (3), a partially-owned parent entity located in the State that owns directly or indirectly an ownership interest in a low-taxed constituent entity at any time during a fiscal year shall be subject to a top-up tax in respect of a low-taxed constituent entity.

(2) Where, subject to subsection (3), a partially-owned 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 partially-owned parent entity is subject to a qualified IIR and owns, directly or indirectly, a controlling interest in the partially-owned parent entity.

Relevant Date: Finance Act 2024