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Amendment of section 246 of Principal Act (interest payments by companies and to non-residents)
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22. (1) Section 246 of the Principal Act is amended in subsection (3) by substituting the following for paragraph (bb):
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“(bb) interest paid in the State—
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(i) by a company to another company, being a company to which paragraph (a) of subsection (5) applies, for so long as that other company is a company to which that paragraph applies, or
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(ii) by a company (in this paragraph referred to as the ‘first-mentioned company’) to which subparagraphs (i) and (ii) of subsection (5)(a) apply to another company resident in the State where that other company is deemed to be a member of the same group of companies as the first-mentioned company and for this purpose the provisions of subsection (1) of section 411 shall apply to determine whether companies are deemed to be members of the same group of companies as if references in that subsection to a 75 per cent subsidiary were references to a 51 per cent subsidiary,”.
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(2) Subsection (1) shall apply to interest paid on or after 1 January 2014.
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