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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 18 December 2023 - onwards
  Version 2 of 2    

835T. Effective tax rate exemption

(1) Section 835R shall not apply in relation to an accounting period of a controlled foreign company where subsection (2) applies.

(2) This subsection applies where the aggregate of the amount of foreign tax and the foreign qualified domestic top-up tax, which is paid, payable or borne by a controlled foreign company for an accounting period, is not less than the difference between -

(a) the aggregate of -

(i) the corresponding corporation tax in the State for that accounting period, and

(ii) the corresponding qualified domestic top-up tax for that accounting period,

and

(b) the aggregate of -

(i) the amount of such foreign tax paid or borne for the accounting period, and

(ii) the amount of foreign qualified domestic top-up tax for the accounting period.

(3) The amount of foreign tax which is paid or borne by a controlled foreign company for an accounting period shall be determined in accordance with section 835N.

(4) In this section -

(a) references to the amount of foreign tax paid o

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