Taxes Consolidation Act 1997 section 111F

Intermediate parent entity in the State

Section 111F sets out when an intermediate parent entity based in Ireland must pay IIR top-up tax in respect of low-taxed constituent entities, and the circumstances in which this obligation does not apply.

• An Irish intermediate parent entity (IPE) must pay IIR top-up tax on any low-taxed constituent entity it holds an interest in, where its ultimate parent entity (UPE) is based in a jurisdiction that has not applied a qualified Income Inclusion Rule (IIR) to that UPE.
• Where the Irish IPE is itself a low-taxed constituent entity, it must also pay IIR top-up tax in respect of itself.
• These obligations do not apply where the UPE is already subject to a qualified IIR for that fiscal year.
• The obligations also do not apply where another IPE higher in the ownership chain is subject to a qualified IIR and holds a controlling interest in the Irish IPE.

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