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Version date: 18 December 2023 - onwards
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111AAQ. Expression of doubt.

(1) In this section -

'law' means one or more provisions of this Part;

'letter of expression of doubt', in relation to a matter, means a communication by electronic means which -

(a) sets out full details of the facts and circumstances of the matter,

(b) specifies the doubt, the basis for the doubt and the law giving rise to the doubt,

(c) identifies the amount of GloBE tax in doubt in respect of the fiscal year to which the expression of doubt relates,

(d) lists or identifies the supporting documentation that is being submitted to the Revenue Commissioners in relation to the matter, and

(e) is clearly identified as a letter of expression of doubt for the purposes of this section,

and a reference to 'an expression of doubt' shall be construed accordingly.

(2) Where an entity is in doubt as to the correct application of the law to any matter to be contained in a GloBE return, required for a fiscal year by this Part, which could -

(a) give rise to a liability to GloBE tax by that entity,

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