Chapter 1 of Part 35 of the Principal Act is amended by the insertion of the following section after section 826A:

"826B.

(1) In this section -

'chargeable period' has the meaning assigned to it by section 321;

'controlling interest' has the meaning assigned to it by section 111A;

'correlative adjustment' means an adjustment of profits under the terms of an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

'effective 90 per cent subsidiary' shall be construed in accordance with subsection (2);

'mutual agreement reached' means an agreement reached between the competent authority of the State and a competent authority of another jurisdiction in accordance with a mutual agreement procedure under an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

'ultimate parent entity' means a company that owns, directly or indirectly, a controlling interest in any other company and that is not owned, directly or indirectly, by another company with a controlling interest in it;

'valid application' shall be construed in accordance with subsection (4).

(2)

(a) Subject to paragraphs (b) and (c), for the purposes of this section, a company shall be an effective 90 per cent subsidiary of another company (in this paragraph referred to as 'the parent company') at any time if at that time -