(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,
(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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