1. Irish Tax Law
  2. Legislation (IE)
  3. Acts
  4. 1997
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  1. Taxes Consolidation Act, 1997 (No. 39)
  2. Income Tax and Corporation Tax: The Main Provisions (ss. 32-531)
  3. Part 4A Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (ss. 111A-111AAAE)
  4. Chapter 1 Interpretation and general (Part 4A) (ss. 111A-111D)
  5. 111D. Location of constituent entity.
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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 18 December 2023 - onwards
    Version 1 of 1    

111D. Location of constituent entity.

(1) Subject to subsections (2) to (9), an entity, other than a flow-through entity, shall for the purposes of this Part, be located in the jurisdiction where it is considered to be resident for tax purposes based on its place of management, its place of creation or similar criteria.

(2) Where it is not possible to determine the location of an entity, other than a flow-through entity, based on where it is considered to be a tax resident in accordance with subsection (1), the entity shall be deemed to be located in the jurisdiction where it was created.

(3)

(a) Where a constituent entity is a flow-through entity and that constituent entity is -

(i) an ultimate parent entity of an MNE group or of a large-scale domestic group, or

(ii) required to apply a qualified IIR,

then, that constituent entity shall be located in the jurisdiction where it was created.

(b) Where a constituent entity is a flow-through entity and paragraph (a) does not apply, the constituent entity shall be considered to

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