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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 18 December 2023 - onwards
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835I. Interpretation

(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 qualified domestic top-up tax payable or borne by a controlled foreign company", means - (a) an amount of foreign qualified domestic top-up tax that is payable or borne by the controlled foreign company, or (b) where an amount of foreign qualified domestic top-up tax is payable or borne by an entity under the laws of the territory in which the controlled foreign company is located, for the purposes of the qualified domestic top-up tax laws of the territory, in respect of the aggregate profits of that controlled foreign compa

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