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 4 Calculation of adjusted covered taxes (ss. 111T-111AB)
  5. 111Z. Specific allocation of covered taxes incurred by certain types of constituent entities.
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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    

111Z. Specific allocation of covered taxes incurred by certain types of constituent entities.

(1) In this section -

'passive income' means the following items of income included in qualifying income to the extent that a constituent entity-owner has been subject to tax under a controlled foreign company tax regime or as a result of an ownership interest in a hybrid entity -

(a) a dividend or dividend equivalents,

(b) interest or interest equivalents,

(c) rent,

(d) royalty,

(e) annuity, or

(f) net gains from assets of a type that produces income referred to in subparagraphs (a) to (e).

(2) A permanent establishment shall be allocated the amount of any covered taxes that are included in the financial accounts of a constituent entity and that relate to the qualifying income or loss of the permanent establishment.

(3) A constituent entity-owner shall be allocated the amount of any covered taxes that are included in the financial accounts of a tax transparent entity and that relate to qualifying income or loss allocated to a constituent entity-owner in accordance with section 111S(4

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