Chapter 2 – IIR and UTPR (ss 111E-111M)

Contents

Section 111E – Ultimate parent entity in the State [TCA 1997 s 111E] Section commentary
Section 111F – Intermediate parent entity in the State [TCA 1997 s 111F] Section commentary
Section 111G – Intermediate parent entity located in the State and held by excluded ultimate parent entity [TCA 1997 s 111G] Section commentary
Section 111H – Partially-owned parent entity in the State [TCA 1997 s 111H] Section commentary
Section 111I – Allocation of top-up tax under IIR [TCA 1997 s 111I] Section commentary
Section 111J – IIR offset mechanism [TCA 1997 s 111J] Section commentary
Section 111K – Effect of qualified domestic top-up tax [TCA 1997 s 111K] Section commentary
Section 111L – Application of UTPR across MNE group [TCA1997 s 111L] Section commentary
Section 111M – Application of UTPR in jurisdiction of ultimate parent entity [TCA 1997 s 111M] Section commentary
Section 111N – Calculation and allocation of UTPR top-up tax amount [TCA 1997 s 111N] Section commentary

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.

Become a member