CHAPTER 3

Exemptions

Overview

Chapter 3 provides for the exemptions to the CFC charge arising under Chapter 2.

835T Effective tax rate exemption

Summary

Section 835T provides for an exemption from the CFC charge where the tax paid by the CFC in its own jurisdiction is not less than half the corresponding corporation tax in the State.

Details

(1) & (2) The CFC charge shall not apply to an accounting period of a CFC where the foreign tax paid by the CFC is equal to or greater than the difference between the corresponding Irish corporation tax and foreign tax.

(3) The amount of foreign tax which is paid by a CFC shall be determined in accordance with the requirements set out under section 835N (Adjustments to amount of foreign tax).

Relevant Date: Finance Act 2021