| Links from Section 835Z | ||
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| Act | Linked to | Context |
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unresolved |
“Directive (EU) 2016/1164” means Council Directive (EU) 2016/1164 of 12 July 20161 laying down rules against tax avoidance practices that directly affect the functioning of the internal market, as amended by Directive (EU) 2017/952; |
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unresolved |
“Directive (EU) 2017/952” means Council Directive (EU) 2017/952 of 29 May 20172 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries; |
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unresolved |
1 OJ No. L193, 19.7.2016, p. 1 |
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unresolved |
2 OJ No. L144, 7.6.2017, p. 1 |
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Taxes Consolidation Act, 1997 |
but does not include an arrangement referred to in section 826; |
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Taxes Consolidation Act, 1997 |
“associated enterprise” shall be construed in accordance with section 835AA; |
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Taxes Consolidation Act, 1997 |
“dual inclusion income” , subject to section 835AB, means any amount which is included in both territories where the mismatch outcome has arisen; |
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Taxes Consolidation Act, 1997 |
“double deduction mismatch outcome” shall be construed in accordance with section 835AD; |
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Taxes Consolidation Act, 1997 |
“permanent establishment deduction without inclusion mismatch outcome” shall be construed in accordance with section 835AG; |
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Taxes Consolidation Act, 1997 |
“financial instrument deduction without inclusion mismatch outcome” shall be construed in accordance with section 835AJ; |
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Taxes Consolidation Act, 1997 |
“payment to a hybrid entity deduction without inclusion mismatch outcome” shall be construed in accordance with section 835AL; |
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Taxes Consolidation Act, 1997 |
“payment by a hybrid entity deduction without inclusion mismatch outcome” shall be construed in accordance with section 835AM; |
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| Links to Section 835Z (from within TaxSource Total) | ||
| Act | Linked from | Context |
|
Taxes Consolidation Act, 1997 |
(b) there is, in substance, a hybrid mismatch (either within the meaning of Directive (EU) 2016/1164 or within the meaning of that term when construed in a manner consistent with its use in the reports referred to in section 835Z(2)). |
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Taxes Consolidation Act, 1997 |
(a) a corresponding amount relating to a payment under a financial instrument shall not be treated as included under paragraph (a)(i) of the definition of “included” in section 835Z(1) where, under the tax laws of the payee territory, the amount that is charged to foreign tax is subject to any reduction computed by reference to the way the payment to which the corresponding amount relates is characterised under those laws, and |
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Taxes Consolidation Act, 1997 |
(b) a corresponding amount relating to a payment under a financial instrument shall not be treated as included under paragraph (a)(i) of the definition of “included” in section 835Z(1) unless— |
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