Taxes Consolidation Act 1997 section 835AP

Application of Chapter 7

Section 835AP identifies the companies to which the tax residency double deduction mismatch rules in this Chapter apply.

• This Chapter targets companies that are simultaneously tax resident in Ireland and in another territory.
• The company must be within the charge to Irish corporation tax because it is tax resident in the State under Irish law.
• The company must also be liable to foreign tax in another territory because it is regarded as tax resident there under that territory's tax laws.
• Where both conditions are met, the double deduction mismatch outcome provisions of section 835AQ apply to the company.