115. Amendment of Part 4A of Principal Act (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)
(1) Part 4A of the Principal Act is amended -
(a) in section 111A -
(i) in subsection (1) -
(I) by the substitution of the following definition for the definition of "hybrid entity":
"'hybrid entity' means -
(a) an entity not treated as fiscally transparent in the jurisdiction where it is located but as fiscally transparent in the jurisdiction in which its owner is located, or
(b) an entity which is located in a jurisdiction that does not have a corporate income tax and the entity -
(i) is treated as fiscally transparent in the jurisdiction where its owner is located, and
(ii) is not treated as a flow-through entity and a tax transparent entity under subsection (5)(c);",
and
(II) by the insertion of the following definitions:
"'securitisation arrangement' means an arrangement that -
(a) is implemented for the purpose of pooling and repackaging a portfolio of assets, or exposures to assets, for investors that are not constituent entities of the MNE group which is undertaking the arrangement, in a manner that legally segregates one or more than one identified pool of assets, and