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 5 Calculation of the effective tax rate and the top-up tax (ss. 111AC-111AK)
  5. 111AJ. Transitional CbCR safe harbour.
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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    

111AJ. Transitional CbCR safe harbour.

(1) In this section -

'country-by-country report' has the same meaning as in section 891H and references in this section to 'CbC report' shall be construed accordingly;

'investment entity jurisdiction' means the jurisdiction in which an investment entity is resident for the purposes of a CbC report;

'multi-parented MNE group' has the meaning assigned to it in section 111AP;

'net unrealised fair value loss' means the sum of all losses, as reduced by any gains, which arise from changes in fair value of ownership interests (other than portfolio shareholdings) included in an MNE group's profit or loss before income tax in respect of a jurisdiction for a fiscal year as reported in its qualified CbC report;

'profit or loss before income tax' means an MNE group's profit or loss before income tax in respect of a jurisdiction for a fiscal year as reported in its qualified CbC report;

'qualified CbC report' means a CbC report prepared and provided using qualified financial statements;

'qualified

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