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Taxes Consolidation Act 1997 section 111I
Allocation of top-up tax under IIR
Section 111I sets out how to calculate the amount of IIR top-up tax a parent entity — being the ultimate parent entity (UPE), an intermediate parent entity (IPE), or a partially-owned parent entity (POPE), as the case may be — must pay in respect of a low-taxed constituent entity, based on the parent's ownership interest in that entity's qualifying income.
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