Taxes Consolidation Act 1997 section 111G

Intermediate parent entity located in the State and held by excluded ultimate parent entity

Section 111G sets out when an intermediate parent entity located in Ireland, whose ultimate parent entity is an excluded entity, is liable to IIR top-up tax in respect of low-taxed constituent entities or itself.

• An Irish-based intermediate parent entity owned (directly or indirectly) by an ultimate parent entity that is an excluded entity must pay IIR top-up tax on the profits of any low-taxed constituent entity it holds an interest in during the fiscal year.
• If the intermediate parent entity is itself a low-taxed constituent entity in a fiscal year, it must pay IIR top-up tax on its own profits for that year.
• These obligations do not apply where another intermediate parent entity in a jurisdiction with a qualified IIR holds a controlling interest in the Irish intermediate parent entity.

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