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 7 Tax neutrality and distribution regimes (ss. 111AQ-111AV)
  5. 111AT. Determination of effective tax rate and top-up tax of investment 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    

111AT. Determination of effective tax rate and top-up tax of investment entity.

(1) Where a constituent entity of an MNE group or large-scale domestic group -

(a) is an investment entity,

(b) is not a tax transparent entity, and

(c) has not made an election in accordance with section 111AU or 111AV,

the effective tax rate of such an investment entity (in this section referred to as a 'relevant investment entity') shall be calculated separately from the effective tax rate of the jurisdiction in which it is located.

(2)

(a) The effective tax rate of a relevant investment entity shall be equal to the relevant investment entity's adjusted covered taxes, as determined in accordance with subsection (3), divided by an amount equal to the allocable share of the MNE group or large-scale domestic group in the qualifying income or loss of the relevant investment entity, as determined in accordance with subsection (5).

(b) Where more than one relevant investment entity is located in a jurisdiction, their effective tax rate shall be calculated by combining their adjusted cover

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