Links from Section 25A | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
(2) For the purposes of section 25(2), the amount of any trading income arising directly or indirectly through or from a branch and any income from property or rights used by, or held by or for, the branch (in this section referred to as ‘relevant branch income’) shall be an amount that is attributable to the branch in accordance with subsections (3) and (4). |
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Taxes Consolidation Act, 1997 |
(12) This section shall not apply to so much of the trade of an overseas life assurance company (within the meaning of section 706) as is life business (within the meaning aforesaid) that is not new basis business (within the meaning of section 730A). |
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Taxes Consolidation Act, 1997 |
(12) This section shall not apply to so much of the trade of an overseas life assurance company (within the meaning of section 706) as is life business (within the meaning aforesaid) that is not new basis business (within the meaning of section 730A). |
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Taxes Consolidation Act, 1997 |
“double taxation relief arrangements” means arrangements having effect by virtue of section 826; |
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Taxes Consolidation Act, 1997 |
(b) For the purpose of determining the effect which would be given if double taxation relief arrangements referred to in paragraph (a)(ii) were to be applied, in accordance with the authorised OECD approach guidance, as required by paragraph (a)(ii), references to ‘Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’ and ‘the Guidelines’ in the authorised OECD approach guidance shall be construed, as far as is practicable, as references to the transfer pricing guidelines (within the meaning of section 835D). |
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Taxes Consolidation Act, 1997 |
(ii) ‘transfer pricing method’, ‘tested party’, ‘selected comparable uncontrolled transactions (internal or external)’, ‘relevant financial indicators for independent enterprises’ and ‘comparable search methodology’ shall be construed in accordance with the transfer pricing guidelines (within the meaning of section 835D). |
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Taxes Consolidation Act, 1997 |
“small enterprise” and “medium enterprise” have the meanings assigned, respectively, to those expressions by section 835F and ‘small or medium-sized enterprise’ shall be construed accordingly. |
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Taxes Consolidation Act, 1997 |
(11)Subsections (3) and (4) of section 886 shall apply with any necessary modifications to the relevant branch records as those provisions apply to the records required by that section. |
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Taxes Consolidation Act, 1997 |
“return” and “specified return date for the accounting period” have the meanings given to them by section 959A; |
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Taxes Consolidation Act, 1997 |
(b) Where the conditions set out in paragraph (c) are met, a relevant branch adjustment shall not be taken into account in determining whether a penalty referred to in section 1077F(2) for a careless default applies to the company for an accounting period or in computing the amount of any such penalty. |
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Links to Section 25A (from within TaxSource Total) | ||
None |