Revenue Note for Guidance
This section sets out the provisions to apply where an election is made under either the group ratio or the equity ratio.
(1) Where a relevant entity makes an election under the group ratio or equity ratio provisions, it must be made before the specified return date for the accounting period to which it relates on the form made available by the Revenue Commissioners.
(2) An election cannot be made under both the group ratio and equity ratio provisions for the same accounting period.
(3) Where a relevant entity is an interest group, and its members include a company which is not a member of a worldwide group, an election cannot be made under the group ratio or equity ratio provisions.
Relevant Date: Finance Act 2021