Taxes Consolidation Act, 1997 (Number 39 of 1997)
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111AAC. Chargeable entities
(1) Subject to section 111AAO, a qualifying entity within the meaning of paragraphs (a) and (b) of section 111AAB(1) shall be chargeable to domestic top-up tax in respect of a fiscal year.
(2) A qualifying entity within the meaning of section 111AAB(1)(c) shall be chargeable to domestic top-up tax in respect of an accounting period.
(3) Where a flow-through entity that is not a body corporate is chargeable to domestic top-up tax by virtue of subsection (1) or (2), the persons who hold an ownership interest in the flow-through entity at any time during the fiscal year or accounting period, as the case may be, are jointly and severally liable to pay the domestic top-up tax.
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(4) (a) Subject to paragraph (b), where a securitisation entity is a member of an MNE group or large-scale domestic group, then no domestic top-up tax shall be charged on that securitisation entity for a fiscal year and for the purposes of determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of that MNE group or large-scale domestic group for the fiscal year, section 111AD(5) shall apply as if the sum, if any, of the qualifying income of all the qualifying entities of that MNE group or largescale domestic group for a fiscal year located in the State excluded the qualifying income, if any, of the securitisation entity.
(b) Paragraph (a) shall not apply where there are no entities of an MNE group or large-scale domestic group located in the State in a fiscal year other than a securitisation entity.
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