(1) The Principal Act is amended by inserting the following Part after Part 35A:
"Part 35B Implementation of Articles 7 and 8 of Council Directive (EU) 2016/1164 of 12 July 2016 (Controlled Foreign Companies)
(1) In this Part -
'accounting profit', in relation to an accounting period of a controlled foreign company, means the amount of profit, before taxation, shown in the profit and loss account, without regard to any -
(a) capital gains or capital losses, or
(b) dividends or other distributions which would be exempted from the charge to tax in determining the controlled foreign company's corresponding chargeable profits in the State;
'amount of foreign tax' means the amount of any tax paid or borne by a controlled foreign company in respect of the controlled foreign company's profits for the accounting period;
'arrangement' means -
(a) any transaction, action, course of action, course of conduct, scheme, plan or proposal,
(b) any agreem
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