1. Irish Tax Law
  2. Legislation (IE)
  3. Acts
  4. 1997
Date-stamp loading
  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 2 IIR and UTPR (ss. 111E-111N)
  5. 111G. Intermediate parent entity located in the State and held by excluded ultimate parent 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    

111G. Intermediate parent entity located in the State and held by excluded ultimate parent entity.

(1) Subject to subsection (3), an intermediate parent entity located in the State -

(a) whose ownership interests are owned directly or indirectly by an ultimate parent entity that is an excluded entity, and

(b) that owns directly or indirectly an ownership interest in a low-taxed constituent entity at any time during a fiscal year,

shall be subject to a top-up tax (in this section referred to as 'IIR top-up tax') in respect of that low-taxed constituent entity for the fiscal year.

(2) Subject to subsection (3), where an intermediate parent entity located in the State, whose ownership interests are owned, directly or indirectly, by an ultimate parent entity that is an excluded entity, is a low-taxed constituent entity in a fiscal year, the intermediate parent entity shall be subject to IIR top-up tax for the fiscal year in respect of itself.

(3) Subsections (1) and (2) shall not apply where another intermediate parent entity is located in a jurisdiction where it is subject to a quali

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