111J IIR Offset Mechanism

This section operates to reduce the top-up tax that has been allocated to a parent entity where that parent entity located in the State holds an ownership interest in a low-taxed constituent entity indirectly through an intermediate parent entity or a partially-owned parent entity that is subject to a qualified IIR for the fiscal year. The allocable share of top-up tax due by the parent entity shall be reduced by the amount allocated to an intermediate parent entity or partially-owned parent entity.

Relevant Date: Finance Act 2024