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Amendment of section 81 (general rule as to deductions) of Principal Act.
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23.— (1) Section 81 of the Principal Act is amended in subsection (2) by substituting “capital gains tax;” for “capital gains tax.” in paragraph (n), and by inserting the following after paragraph (n):
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“(o) any sum paid or payable under any agreement or understanding whereby a person is obliged to make a payment to a connected person resident in any territory outside the State for an adjustment made, or to be made, to the profits of the connected person for which relief may be afforded under the terms of an arrangement entered into by virtue of subsection (1) or (1B) of section 826, or for a similar adjustment made to the profits of a connected person resident in any other territory.”.
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(2) (a) Subsection (1) applies in respect of any sum paid or payable—
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(i) in an accounting period ending on or after 20 November 2008, or
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(ii) in a basis period for a year of assessment where that basis period ends on or after 20 November 2008.
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(b) For the purposes of this subsection “basis period” means the period on the profits or gains of which income tax for the year of assessment is to be finally computed under the Income Tax Acts.
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