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AI Summary of Article 10 IIR offset mechanism

Version status: Entered into force | Document consolidation status: Updated to reflect all known changes
Version date: 23 December 2022 - onwards
Version 2 of 2

Article 10 IIR offset mechanism

Where a parent entity located in a Member State holds an ownership interest in a low-taxed constituent entity indirectly through an intermediate parent entity or a partially-owned parent entity that is subject to a qualified IIR for the fiscal year, the top-up tax due pursuant to Articles 5 to 8 shall be reduced by an amount equal to the portion of the first-mentioned parent entity's allocable share of the top-up tax which is due by the intermediate parent entity or the partially-owned parent entity.