(1) In this section, 'participation' means -
(a) a, direct or indirect, possession of, or beneficial right to, or right to acquire, share capital or issued share capital of a company,
(b) a, direct or indirect, right to exercise, or to acquire the rights to exercise the voting power of a company, or
(c) a beneficial right to any profits available for distribution to equity holders of a company.
(2) Subject to subsections (5), (9) and (10), where in an accounting period of a controlled foreign company -
(a) a controlled foreign company group has undistributed income, and
(b) relevant Irish activities in relation to the controlled foreign company group are performed by a chargeable company,
a controlled foreign company charge shall be made on the chargeable company for the accounting period of the chargeable company, as determined in accordance with section 27, in which the accounting period of the controlled foreign company ends.
(3) The controlled foreign company charge made under subs
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