Paschal Donohoe (Dublin Central, Fine Gael)
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I move amendment No. 56:

In page 61, to delete lines 29 to 32 and substitute the following:

“but for the fact that the amount against which the payment is deductible in the payer territory is a disregarded payment in the first-mentioned territory,

the disregarded payment shall be treated as included in the first-mentioned territory.

(3) This section shall not apply where—

(a) the disregarded payments are between—

(i) where the entity referred to in subsection (1) is a participator in a hybrid entity, the entity and the hybrid entity, or

(ii) where the entity referred to in subsection (1) is a participator in two or more hybrid entities, two or more such hybrid entities,

and

(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)).”.