107. Apportionment of profits. | Taxes Consolidation Act, 1997 (No. 39) | Better Regulation

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Taxes Consolidation Act, 1997 (No. 39)Introductory Text Acts Referred to Interpretation and basic charging provisions (ss. 1-31)Part 1 Interpretation (ss. 1-11)1. Interpretation of this Act.2. Interpretation of Tax Acts.3. Interpretation of Income Tax Acts.4. Interpretation of Corporation Tax Acts.5. Interpretation of Capital Gains Tax Acts.6. Construction of references to child in Tax Acts and Capital Gains Tax Acts.7. Application to certain taxing statutes of Age of Majority Act, 1985.8. Construction of certain taxing statutes in accordance with Status of Children Act, 1987.9. Subsidiaries.10. Connected persons.11. Meaning of "control" in certain contexts.Part 2 The Charge to Tax (ss. 12-31)Chapter 1 Income tax (ss. 12-20)12. The charge to income tax.13. Extension of charge to income tax to profits and income derived from activities carried on and employments exercised on the Continental Shelf.14. Fractions of a pound and yearly assessments.15. Rate of charge.16. Income tax charged by deduction.17. Schedule C.18. Schedule D.19. Schedule E.20. Schedule F.Chapter 2 Corporation tax (ss. 21-27)21. The charge to corporation tax and exclusion of income tax and capital gains tax.21A. Higher rate of corporation tax.21B. Tax treatment of certain dividends.22. Reduced rate of corporation tax for certain income.22A. Reduction of corporation tax liability in respect of certain trading income.23. Application of section 13 for purposes of corporation tax.23A. Company residence.23B. Residence of SE or SCE.24. Companies resident in the State: income tax on payments made or received.25. Companies not resident in the State.25A. Attribution of profits to a branch.26. General scheme of corporation tax.27. Basis of, and periods for, assessment.Chapter 3 Capital gains tax (ss. 28-31)28. Taxation of capital gains and rate of charge.29. Persons chargeable.29A. Temporary non-residents.30. Partnerships.31. Amount chargeable.Income Tax and Corporation Tax: The Main Provisions (ss. 32-531)Part 3 Provisions Relating to the Schedule C Charge and Government and Other Public Securities (ss. 32-51)Chapter 1 Principal provisions relating to the Schedule C charge (ss. 32-35)32. Interpretation (Chapter 1).33. Method of charge and payment.34. Stock, dividends or interest belonging to the State.35. Securities of foreign territories.Chapter 2 Government and other public securities: interest payable without deduction of tax (ss. 36-41)36. Government securities.37. Securities of certain State-owned companies.38. Certain State-guaranteed securities.39. Securities of certain European bodies.40. Securities of International Bank for Reconstruction and Development.41. Securities of designated bodies under the Securitisation (Proceeds of Certain Mortgages) Act, 1995.Chapter 3 Government and other public securities: exemptions from tax (ss. 42-50)42. Exemption of interest on savings certificates.43. Certain securities issued by Minister for Finance.44. Exemption from corporation tax of certain securities issued by Minister for Finance.45. Exemption of non-interest-bearing securities.46. Exemption of premiums on Investment Bonds.47. Certain securities of ACC Bank plc.48. Exemption of premiums on certain securities.49. Exemption of certain securities.50. Securities of Irish local authorities issued abroad.Chapter 4 Miscellaneous provisions (s. 51)51. Funding bonds issued in respect of interest on certain debts.Part 4 Principal Provisions Relating to the Schedule D Charge (ss. 52-111)Chapter 1 Supplementary charging provisions (ss. 52-59)52. Persons chargeable.53. Cattle and milk dealers.54. Interest, etc. paid without deduction of tax under Schedule C.55. Taxation of strips of securities.56. Tax on quarries, mines and other concerns chargeable under Case I(b) of Schedule D.57. Extension of charge to tax under Case III of Schedule D in certain circumstances.58. Charge to tax of profits or gains from unknown or unlawful source.59. Charge to tax of income from which tax has been deducted.Chapter 2 Foreign dividends (ss. 60-64)60. Interpretation (Chapter 2).61. Dividends entrusted for payment in the State.62. Dividends paid outside the State and proceeds of sale of dividend coupons.63. Exemption of dividends of non-residents.64. Interest on quoted Eurobonds.Chapter 3 Income tax: basis of assessment under Cases I and II (ss. 65-69)65. Cases I and II: basis of assessment.66. Special basis at commencement of trade or profession.67. Special basis on discontinuance of trade or profession.68. Short-lived businesses.69. Changes of proprietorship.Chapter 4 Income tax: basis of assessment under Cases III, IV and V (ss. 70-75)70. Case III: basis of assessment.71. Foreign securities and possessions.72. Charge to tax on sums applied outside the State in repaying certain loans.73. Income from certain possessions in Great Britain or Northern Ireland.74. Case IV: basis of assessment.75. Case V: basis of assessment.Chapter 5 Computational provisions: corporation tax (ss. 76-80A)76. Computation of income: application of income tax principles.76A. Computation of profits or gains of a company - accounting standards.76B. Treatment of unrealised gains and losses in certain cases.76C. Use of different accounting policies within a group of companies.76D. Computation of income and expenses from leases.76E. Computation of profits and gains: deductions for interest paid by qualifying financing companies.77. Miscellaneous special rules for computation of income.78. Computation of companies' chargeable gains.79. Foreign currency: computation of income and chargeable gains.79A. Matching of relevant foreign currency assets with foreign currency liabilities.79B. Matching of foreign currency assets with certain foreign currency share capital.79C. Exclusion of foreign currency as asset of certain companies.80. Taxation of certain foreign currencies.80A. Taxation of certain short-term leases plant and machinery.Chapter 6 Computational provisions: general (ss. 81-88A)81. General rule as to deductions.81A. Restriction of deductions for employee benefit contributions.81B. Equalisation reserves for credit insurance and reinsurance business of companies.81C. Emissions allowances.81D. Deduction for stock exchange listing expenditure.81E. Enhanced deduction for eligible construction expenditure.82. Pre-trading expenditure.83. Expenses of management of investment companies.83A. Expenditure involving crime.84. Expenses in relation to establishment or alteration of superannuation schemes.85. Deduction for certain industrial premises.86. Cost of registration of trade marks.87. Debts set off against profits and subsequently released.87A. Deductions for gifts to Foundation for Investing in Communities.87B. Release of debts in certain trades.88. Deduction for gifts to Enterprise Trust Ltd.88A. Double deduction in respect of certain emoluments.Chapter 7 Special measures on discontinuance of, and change of basis of computation of profits or gains of, a trade or profession (ss. 89-95A)89. Valuation of trading stock at discontinuance of trade.90. Valuation of work in progress at discontinuance of profession.91. Receipts accruing after discontinuance of trade or profession.92. Receipts and losses accruing after change treated as discontinuance.93. Cash basis, etc: relief for certain individuals.94. Conventional basis: general charge on receipts after change of basis.95. Supplementary provisions as to tax under section 91 or 94.95A. Change of basis of computation of profits or gains of a trade or profession.Chapter 8 Taxation of rents and certain other payments (ss. 96-106A)96. Interpretation (Chapter 8).97. Computational rules and allowable deductions.97A. Pre-letting expenditure in respect of vacant premises.97B. Deduction for retrofitting expenditure.98. Treatment of premiums, etc. as rent.98A. Taxation of reverse premiums.99. Charge on assignment of lease granted at undervalue.100. Charge on sale of land with right to reconveyance.100A. Appeals against determinations under sections 98 to 100.101. Relief for amount not received.102. Deduction by reference to premium, etc. paid in computation of profits for purposes of Schedule D, Cases I and II.103. Deduction by reference to premiums, etc. paid in computation of profits for purposes of this Chapter.104. Taxation of certain rents and other payments.105. Taxation of rents: restriction in respect of certain rent and interest.106. Tax treatment of receipts and outgoings on sale of premises.106A. Transfer of rent.Chapter 9 Miscellaneous provisions (ss. 107-111)107. Apportionment of profits.108. Statement of profits.109. Payments in respect of redundancy.110. Securitisation.111. Allowance to owner of let mineral rights for expenses of management of minerals.Part 4A Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (ss. 111A-111AAAE)Chapter 1 Interpretation and general (Part 4A) (ss. 111A-111D)111A. Interpretation (Part 4A).111B. Principles for construing rules in accordance with OECD Pillar Two guidance.111C. Scope of Part 4A.111D. Location of constituent entity.Chapter 2 IIR and UTPR (ss. 111E-111N)111E. Ultimate parent entity in the State.111F. Intermediate parent entity in the State.111G. Intermediate parent entity located in the State and held by excluded ultimate parent entity.111H. Partially-owned parent entity in the State.111I. Allocation of top-up tax under IIR.111J. IIR offset mechanism.111K. Effect of qualified domestic top-up tax.111L. Application of UTPR across MNE group.111M. Application of UTPR in jurisdiction of ultimate parent entity.111N. Calculation and allocation of UTPR top-up tax amount.Chapter 3 Calculation of the qualifying income or loss (ss. 111O-111S)111O. Determination of qualifying income or loss.111P. Adjustments to determine qualifying income or loss.111Q. International shipping income exclusion.111R. Allocation of qualifying income or loss between main entity and permanent establishment.111S. Allocation of qualifying income or loss of flow-through entity.Chapter 4 Calculation of adjusted covered taxes (ss. 111T-111AB)111T. Covered taxes.111U. Adjusted covered taxes.111V. Meaning of marketable transferable tax credit.111W. Equity investment inclusion election and qualified flow-through tax benefits of qualified ownership interests.111X. Total deferred tax adjustment amount.111Y. Qualifying loss election.111Z. Specific allocation of covered taxes incurred by certain types of constituent entities.111AA. Rules required for blended CFC regime.111AB. Post-filing adjustments and tax rate changes.Chapter 5 Calculation of the effective tax rate and the top-up tax (ss. 111AC-111AKA)111AC. Determination of effective tax rate.111AD. Calculation of top-up tax.111AE. Substance-based income exclusion.111AF. Additional top-up tax.111AG. De minimis exclusion.111AH. Minority owned constituent entities.111AI. Qualified domestic top-up tax safe harbour.111AJ. Transitional CbCR safe harbour.111AK. Transitional UTPR safe harbour.111AKA. Simplified calculations safe harbour Chapter 6 Corporate restructuring and holding structures (ss. 111AL-111AP)111AL. Application of consolidated revenue threshold to group mergers and demergers.111AM. Constituent entities joining and leaving MNE group or large-scale domestic group.111AN. Transfer of assets and liabilities.111AO. Joint ventures.111AP. Multi-parented MNE and large-scale domestic groups.Chapter 7 Tax neutrality and distribution regimes (ss. 111AQ-111AV)111AQ. Ultimate parent entity that is a flow-through entity.111AR. Ultimate parent entity subject to a deductible dividend regime.111AS. Eligible distribution tax systems.111AT. Determination of effective tax rate and top-up tax of investment entity.111AU. Election to treat investment entity as tax transparent entity.111AV. Election to apply taxable distribution method.Chapter 8 Transition Rules (ss. 111AW-111AZ)111AW. Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition.111AX. Transitional relief for substance-based income exclusion.111AY. Initial phase of exclusion from IIR and UTPR of MNE groups and large-scale domestic groups.111AZ. Delayed application of IIR and UTPR by Member States.Chapter 9 Domestic Top-up Tax (ss. 111AAA-111AAE)111AAA. Interpretation (Chapter 9).111AAB. Qualifying entities.111AAC. Chargeable entities.111AAD. Determining top-up amounts of qualifying entity.111AAE. Scope of application of qualifying domestic top-up tax.Chapter 10 Administration (ss. 111AAF-111AAAD)111AAF. Interpretation (Chapter 10).111AAG. Care and management.111AAH. Obligation to register.111AAI. Top-up tax information return.111AAJ. IIR return and self-assessment.111AAK. UTPR return and self-assessment.111AAL. UTPR group.111AAM. UTPR group recovery.111AAN. QDTT return and self-assessment.111AAO. QDTT group.111AAP. QDTT group recovery.111AAQ. Expression of doubt.111AAR. Actions by person acting under authority.111AAS. Date for payment.111AAT. Assessments and enquiries.111AAU. Revenue assessment.111AAV. Notice of Revenue assessment.111AAW. Appeal to Appeal Commissioners.111AAX. Surcharge for late return.111AAY. Interest on overdue amounts.111AAZ. Obligation to keep certain records.111AAAA. Use of currency.111AAAB. Penalties.111AAAC. Transitional simplified jurisdictional reporting.111AAAD. Elections.Chapter 11 Application (s. 111AAAE)111AAAE. Application (Part 4A).Part 5 Principal Provisions Relating to the Schedule E Charge (ss. 112-128F)Chapter 1 Basis of assessment, persons chargeable and extent of charge (s. 112-112B)112. Basis of assessment, persons chargeable and extent of charge.112A. Taxation of certain perquisites.112AA. Taxation of certain perquisites: employees of authorised insurers and tied health insurance agents.112B. Granting of vouchers.Chapter 2 Computational provisions (ss. 113-115)113. Making of deductions.114. General rule as to deductions.114A. Deduction in respect of certain expenses of remote working.115. Fixed deduction for certain classes of persons.Chapter 3 Expenses allowances and provisions relating to the general benefits in kind charge (ss. 116-120B)116. Interpretation (Chapter 3).117. Expenses allowances.118. Benefits in kind: general charging provision.118A. Costs and expenses in respect of personal security assets and services.118B. Revenue approved salary sacrifice agreements.119. Valuation of benefits in kind.120. Unincorporated bodies, partnerships and individuals.120A. Exemption from benefit-in-kind of certain childcare facilities.120B. Certain benefits in kind: members of Permanent Defence Force.Chapter 4 Other benefit in kind charges (ss. 121-122A)121. Benefit of use of car.121A. Benefit of use of van.122. Preferential loan arrangements.122A. Notional loans relating to shares, etc.Chapter 5 Miscellaneous charging provisions (ss. 123-128F)123. General tax treatment of payments on retirement or removal from office or employment.124. Tax treatment of certain severance payments.124A. Tax treatment of payments made pursuant to an order under section 2B of Employment Permits Act 2003.125. Tax treatment of benefits received under permanent health benefit schemes.126. Tax treatment of certain benefits payable under Social Welfare Acts.127. Tax treatment of restrictive covenants.127A. Tax treatment of members of the European Parliament.127B. Tax treatment of flight crew in international traffic.128. Tax treatment of directors of companies and employees granted rights to acquire shares or other assets.128A. Deferral of payment of tax under section 128.128B. Payment of tax under section 128.128C. Tax treatment of directors and employees who acquire convertible securities.128D. Tax treatment of directors of companies and employees who acquire restricted shares.128E. Tax treatment of directors of companies and employees who acquire forfeitable shares.128F. Key Employee Engagement Programme.Part 6 Company Distributions, Tax Credits, Franked Investment Income and Advance Corporation Tax (ss. 129-186)Chapter 1 Taxation of company distributions (ss. 129-129A)129. Irish resident company distributions not generally chargeable to corporation tax.129A. Dividends paid out of foreign profits.Chapter 2 Meaning of distribution (ss. 130-135)130. Matters to be treated as distributions.131. Bonus issues following repayment of share capital.132. Matters to be treated or not treated as repayments of share capital.133. Limitation on meaning of "distribution" - general.134. Limitation on meaning of "distribution" in relation to certain payments made in respect of "foreign source" finance.135. Distributions: supplemental.Chapter 3 Distributions and tax credits - general (ss. 136-139)136. Tax credit for certain recipients of distributions.137. Disallowance of reliefs in respect of bonus issues.138. Treatment of dividends on certain preference shares.139. Dividends and other distributions at gross rate or of gross amount.Chapter 4 Distributions out of certain exempt profits or gains or out of certain relieved income (ss. 140-146)140. Distributions out of profits or gains from stallion fees, stud greyhound services fees and occupation of certain woodlands.141. Distributions out of income from patent royalties.142. Distributions out of profits of certain mines.143. Distributions out of profits from coal, gypsum and anhydrite mining operations.144. Distributions out of profits from trading within Shannon Airport.145. Distributions out of profits from export of certain goods.146. Provisions supplementary to section 145.Chapter 5 Distributions out of certain income of manufacturing companies (ss. 147-151)147. Distributions.148. Treatment of certain deductions in relation to relevant distributions.149. Dividends and other distributions at gross rate or of gross amount.150. Tax credit for recipients of certain distributions.151. Appeals.Chapter 6 Distributions - supplemental (ss. 152-155)152. Explanation of tax credit to be annexed to interest and dividend warrants.153. Distributions to certain non-residents.154. Attribution of distributions to accounting periods.155. Restriction of certain reliefs in respect of distributions out of certain exempt or relieved profits.Chapter 7 Franked investment income (ss. 156-158)156. Franked investment income and franked payments.157. Set-off of losses, etc. against franked investment income.158. Set-off of loss brought forward or terminal loss against franked investment income in the case of financial concerns.Chapter 8 Advance corporation tax (ss. 159-172)159. Liability for advance corporation tax.160. Set-off of advance corporation tax.161. Rectification of excessive set-off of advance corporation tax.162. Calculation of advance corporation tax where company receives distributions.163. Tax credit recovered from company.164. Restrictions as to payment of tax credit.165. Group dividends.166. Surrender of advance corporation tax.167. Change of ownership of company: calculation and treatment of advance corporation tax.168. Distributions to certain non-resident companies.169. Non-distributing investment companies.170. Interest in respect of certain securities.171. Returns, payment and collection of advance corporation tax.172. Application of Corporation Tax Acts.Chapter 8A Dividend withholding tax (ss. 172A-172M)172A. Interpretation.172B. Dividend withholding tax on relevant distributions.172BA. Obligation on certain persons to obtain tax reference numbers of persons beneficially entitled to relevant distributions.172C. Exemption from dividend withholding tax for certain persons.172D. Exemption from dividend withholding tax for certain non-resident persons.172E. Qualifying intermediaries.172F. Obligations of qualifying intermediary in relation to relevant distributions.172FA. Recognised qualifying intermediaries.172G. Authorised withholding agent.172H. Obligations of authorised withholding agent in relation to relevant distributions.172I. Statement to be given to recipients of relevant distributions.172J. Credit for, or repayment of, dividend withholding tax borne.172K. Returns, payment and collection of dividend withholding tax.172L. Reporting of distributions made under stapled stock arrangements.172LA. Deduction of dividend withholding tax on settlement of market claims.172M. Delegation of powers and functions of Revenue Commissioners.Chapter 9 Taxation of acquisition by a company of its own shares (ss. 173-186)173. Interpretation (Chapter 9).174. Taxation of dealer's receipts on purchase of shares by issuing company or by its subsidiary.175. Purchase of own shares by quoted company.176. Purchase of unquoted shares by issuing company or its subsidiary.176A. Purchase of own shares - supplementary.177. Conditions as to residence and period of ownership.178. Conditions as to reduction of vendor's interest as shareholder.179. Conditions applicable where purchasing company is member of a group.180. Additional conditions.181. Relaxation of conditions in certain cases.182. Returns.183. Information.184. Treasury shares.185. Associated persons.186. Connected persons.Part 7 Income Tax and Corporation Tax Exemptions (ss. 187-236)Chapter 1 Income tax (ss. 187-216F)Draft 192Q Exemption in respect of State contribution under automatic enrolment retirement savings system 187. Exemption from income tax and associated marginal relief.188. Age exemption and associated marginal relief.189. Payments in respect of personal injuries.189A. Special trusts for permanently incapacitated individuals.189B. Exemption in respect of periodic payments for personal injuries.190. Certain payments made by the Haemophilia HIV Trust.191. Taxation treatment of Hepatitis C compensation payments.192. Payments in respect of thalidomide children.192A. Exemption in respect of certain payments under employment law.192B. Foster care payments etc.192BA. Exemption of certain payments made or authorised by Child and Family Agency.192C. Exemption in respect of payments of State support.192D. Exemption in respect of fuel grant.192E. Exemption in respect of water conservation grant.192F. Exemption in respect of certain education-related payments.192G. Exemption in respect of training allowance payments.192H. Exemption in respect of Mobility Allowance.192I. Exemption in respect of Pandemic Placement Grant.192J. Exemption in respect of electricity costs emergency benefit payment.192JA. Exemption in respect of payments under Electricity Costs Emergency Benefit Scheme II.192JB. Exemption in respect of electricity costs emergency benefit payment and submeter support scheme payment.192JC. Exemption in respect of payments under Electricity Costs Emergency Benefit Scheme IV and Submeter Support Scheme II.192K. Exemption in respect of Pandemic Special Recognition Payment.192L. Exemption in respect of incorrect birth registration payment.192M. Exemption in respect of payments under Covid-19 Death in Service Ex-Gratia Scheme for Health Care Workers.192N. Exemption of payments in relation to Ex-Gratia Scheme for Community Employment Scheme Supervisors and Assistant Supervisors.192O. Exemption in respect of Clinical Placement Allowance.192P. Exemption in respect of allowance for maternity-related administrative support.192Q. Exemption in respect of State contribution under automatic enrolment retirement savings system 193. Income from scholarships.194. Child benefit.194A. Early childcare supplement.194AA. Exemption of certain childcare support payments.194B. Back to work family dividend.195. Exemption of certain earnings of writers, composers and artists.195A. Exemption in respect of certain expense payments.195B. Exemption in respect of certain expense payments for relevant directors.195C. Exemption in respect of certain expenses of State Examinations Commission examiners.195D. Exemption in respect of certain expense payments for resident relevant directors.195E. Exemption in respect of certain expenses of members of Disabled Drivers Medical Board of Appeal.196. Expenses of members of judiciary.196A. State employees: foreign service allowances.196B. Employees of certain agencies: foreign service allowances.197. Bonus or interest paid under instalment savings schemes.198. Certain interest not to be chargeable.199. Interest on certain securities.200. Certain foreign pensions.200A. Lump sums from foreign pension arrangements.201. Exemptions and reliefs in respect of tax under section 123.202. Relief for agreed pay restructuring.203. Payments in respect of redundancy.204. Military and other pensions, gratuities and allowances.204A. Exemption in respect of annual allowance for reserve members of the Garda Síochána.204B. Exemption in respect of compensation for certain living donors.205. Veterans of War of Independence.205A. Magdalen Laundry Payments.205B. Payments under Mother and Baby Institutions Payment Scheme Act 2023.205C. Exemption in respect of CervicalCheck payments 205D. Exemption in respect of Stardust ex-gratia payments 206. Income from investments under Social Welfare (Consolidation) Act, 1993.207. Rents of properties belonging to hospitals and other charities.207A. Charities Regulatory Authority and Common Investment Fund.208. Lands owned and occupied, and trades carried on by, charities.208A. Provisions relating to charities and donations to approved bodies.208B. Charities - miscellaneous.209. Bodies for the promotion of Universal Declaration of Human Rights and the implementation of European Convention for the Protection of Human Rights and Fundamental Freedoms.210. The Great Book of Ireland Trust.211. Friendly societies.212. Credit unions.213. Trade unions.214. Local authorities, etc.215. Certain profits of agricultural societies.216. Profits from lotteries.216A. Rent-a-room relief.216B. Payments under Scéim na bhFoghlaimeoirí Gaeilge.216C. Childcare services relief.216D. Certain profits of micro-generation of electricity.216E. Payments under Part 2 of the Civil Law (Miscellaneous Provisions) Act 2022.216F. Exemption of certain profits arising from production, maintenance and repair of certain musical instruments.Chapter 2 Corporation tax (ss. 217-222A)217. Certain income of Nítrigin Éireann Teoranta.218. Certain income of Housing Finance Agency plc.218A. Certain income of Motor Insurers' Bureau of Ireland.219. Income of body designated under Irish Takeover Panel Act, 1997.219A. Income of credit unions.219B. Income of Investor Compensation Company Ltd.220. Profits of certain bodies corporate.221. Certain payments to National Co-operative Farm Relief Services Ltd and certain payments made to its members.222. Certain dividends from a non-resident subsidiary.222A. Exemption of certain profits or gains arising from cost rental properties.Chapter 3 Income tax and corporation tax (ss. 223-236)223. Small enterprise grants.224. Grants to medium and large industrial undertakings.225. Employment grants.226. Certain employment grants and recruitment subsidies.227. Certain income arising to specified non-commercial state-sponsored bodies.228. Income arising to designated bodies under the Securitisation (Proceeds of Certain Mortgages) Act, 1995.229. Harbour authorities and port companies.229A. Shannon Commercial Enterprises Ltd.230. National Treasury Management Agency.230A. National Pensions Reserve Fund Commission.230AA. NAMA profits exempt from corporation tax.230AB. National Development Finance Agency.230AC. Tax exemptions.231. Profits or gains from stallion fees.232. Profits from occupation of certain woodlands.233. Stud greyhound service fees.234. Certain income derived from patent royalties.235. Bodies established for promotion of athletic or amateur games or sports.235A. Exemption for certain sporting national governing bodies.236. Loan of certain art objects.Part 8 Annual Payments, Charges and Interest (ss. 237-267M)Chapter 1 Annual payments (ss. 237-242A)237. Annual payments payable wholly out of taxed income.238. Annual payments not payable out of taxed income.239. Income tax on payments by resident companies.240. Provisions as to tax under section 239.241. Income tax on payments by non-resident companies.242. Annual payments for non-taxable consideration.242A. Tax treatment of certain royalties.Chapter 2 Charges on income for corporation tax purposes (ss. 243-243B)243. Allowance of charges on income.243A. Restriction of relevant charges on income.243B. Relief for certain charges on income on a value basis.Chapter 3 Principal provisions relating to the payment of interest (ss. 244-255)244. Relief for interest paid on certain home loans.244A. Application of section 244 (relief for interest paid on certain home loans) of Principal Act.245. Relief for certain bridging loans.246. Interest payments by companies and to non-residents.246A. Interest in respect of wholesale debt instruments.247. Relief to companies on loans applied in acquiring interest in other companies.248. Relief to individuals on loans applied in acquiring interest in companies.248A. Restriction of relief in respect of loans applied in acquiring interest in companies and partnerships.249. Rules relating to recovery of capital and replacement loans.250. Extension of relief under section 248 to certain individuals in relation to loans applied in acquiring interest in certain companies.250A. Restriction of relief to individuals in respect of loans applied in acquiring interest in companies.251. Restriction of relief to individuals on loans applied in acquiring shares in companies where a claim for "BES relief" or "film relief" is made in respect of amount subscribed for shares.252. Restriction of relief to individuals on loans applied in acquiring interest in companies which become quoted companies.253. Relief to individuals on loans applied in acquiring interest in partnerships.254. Interest on borrowings to replace capital withdrawn in certain circumstances from a business.255. Arrangements for payment of interest less tax or of fixed net amount.Chapter 4 Interest payments by certain deposit takers (ss. 256-267)256. Interpretation (Chapter 4).257. Deduction of tax from relevant interest.258. Returns and collection of appropriate tax.259. Alternative amount on account of appropriate tax.260. Provisions supplemental to sections 258 and 259.261. Taxation of relevant interest, etc.261A. Taxation of interest on special term accounts.261B. Taxation of specified interest.262. Statement furnished by relevant deposit taker.263. Declarations relating to deposits of non-residents.263A. Declarations to a relevant deposit taker relating to deposits of certain persons.263B. Declarations to the Revenue Commissioners relating to deposits of certain persons.263C. Notifications by the Revenue Commissioners relating to deposits of certain persons.263D. Declarations to the Revenue Commissioners in relation to relevant amounts.263E. Notification by the Revenue Commissioners relating to deposits of relevant amounts.263F. Declarations relating to deposits made by a PEPP provider held for a PEPP.264. Conditions and declarations relating to special savings accounts.264A. Conditions and declarations relating to special term accounts.264B. Returns of special term accounts by relevant deposit takers.265. Deposits of companies and pensions schemes.265A. Deposits of certain persons.266. Deposits of charities.266A. Repayments of appropriate tax to first-time purchasers.267. Repayment of appropriate tax in certain cases.Chapter 5 Dividend Payments by Credit Unions (ss. 267A-267F)267A. Interpretation (Chapter 5).267AA. Taxation of dividends on regular share accounts.267B. Election to open a special share account or a special term share account.267C. Taxation of dividends on special term share accounts.267D. Conditions and declarations relating to special term share accounts.267E. Returns of special term share accounts by credit unions.267F. Supplementary provisions (Chapter 5).Chapter 6 Implementation of Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (ss. 267G-267L)267G. Interpretation (Chapter 6).267H. Application (Chapter 6).267I. Exemptions from tax and withholding tax.267J. Credit for foreign tax.267K. Miscellaneous.267L. Application of this Chapter to certain payments made to companies in Switzerland.Chapter 7 Certain interest from sources outside the State (s. 267M)267M. Tax rate applicable to certain deposit interest received by individuals.Part 8A Specified Financial Transactions (ss. 267N-267V)Chapter 1 Interpretation (s. 267N)267N. Interpretation.Chapter 2 Credit Return (ss. 267O-267P)267O. Treatment of credit return.267P. Treatment of credit transaction.Chapter 3 Deposit Return (s. 267Q)267Q. Treatment of deposit return.Chapter 4 Investment Certificates and Returns (ss. 267R-267S)267R. Treatment of investment return.267S. Treatment of certificate owner.Chapter 5 Reporting (ss. 267T)267T. Reporting.Chapter 6 Application (ss. 267U-267V)267U. Application.267V. Transactions to avoid tax.Part 9 Principal Provisions Relating to Relief for Capital Expenditure (ss. 268-321)Chapter 1 Industrial buildings or structures: industrial building allowances, writing-down allowances, balancing allowances and balancing charges (ss. 268-282)268. Meaning of "industrial building or structure".269. Meaning of "the relevant interest".270. Meaning of "expenditure on construction of building or structure".271. Industrial building allowances.272. Writing-down allowances.273. Acceleration of writing-down allowances in respect of certain expenditure on certain industrial buildings or structures.274. Balancing allowances and balancing charges.275. Restriction of balancing allowances on sale of industrial building or structure.276. Application of sections 272 and 274 in relation to capital expenditure on refurbishment.277. Writing off of expenditure and meaning of "residue of expenditure".278. Manner of making allowances and charges.279. Purchases of certain buildings or structures.280. Temporary disuse of building or structure.281. Special provisions in regard to leases.282. Supplementary provisions (Chapter 1).Chapter 2 Machinery or plant: initial allowances, wear and tear allowances, balancing allowances and balancing charges (ss. 283-301)283. Initial allowances.284. Wear and tear allowances.285. Acceleration of wear and tear allowances.285A. Acceleration of wear and tear allowances for certain energy-efficient equipment.285B. Acceleration of wear and tear allowances for childcare and fitness centre equipment.285C. Acceleration of wear and tear allowances for gas vehicles and refuelling equipment.285D. Acceleration of wear and tear allowances for farm safety equipment.286. Increased wear and tear allowances for taxis and cars for short-term hire.286A. Wear and tear allowances for licences for public hire vehicles.287. Wear and tear allowances deemed to have been made in certain cases.288. Balancing allowances and balancing charges.289. Calculation of balancing allowances and balancing charges in certain cases.290. Option in case of replacement.291. Computer software.291A. Intangible assets.292. Meaning of "amount still unallowed".293. Application to partnerships.294. Machinery or plant used partly for non-trading purposes.295. Option in case of succession under will or intestacy.296. Balancing allowances and balancing charges: wear and tear allowances deemed to have been made in certain cases.297. Subsidies towards wear and tear.298. Allowances to lessors.299. Allowances to lessees.300. Manner of making allowances and charges.301. Application to professions, employments and offices.Chapter 3 Dredging: initial allowances and annual allowances (ss. 302-303)302. Interpretation (Chapter 3).303. Allowances for expenditure on dredging.Chapter 4 Miscellaneous and general (ss. 304-321)304. Income tax: allowances and charges in taxing a trade, etc.305. Income tax: manner of granting, and effect of, allowances made by means of discharge or repayment of tax.306. Meaning of basis period.307. Corporation tax: allowances and charges in taxing a trade.308. Corporation tax: manner of granting, and effect of, allowances made by means of discharge or repayment of tax.308A. Assets transferred in course of scheme of reconstruction or amalgamation.309. Companies not resident in the State.310. Allowances in respect of certain contributions to capital expenditure of local authorities.311. Apportionment of consideration and exchanges and surrenders of leasehold interests.312. Special provisions as to certain sales.313. Effect, in certain cases, of succession to trade, etc.314. Procedure on apportionment.315. Property used for purposes of "exempted trading operations".316. Interpretation of certain references to expenditure and time when expenditure is incurred.317. Treatment of grants.318. Meaning of "sale, insurance, salvage or compensation moneys".319. Adjustment of allowances by reference to value-added tax.320. Other interpretation (Part 9).321. Provisions of general application in relation to the making of allowances and charges.Part 10 Income Tax and Corporation Tax: Reliefs for Renewal and Improvement of Certain Urban Areas, Certain Resort Areas and Certain Islands (ss. 322-372AAC)Chapter 1 Custom House Docks Area (ss. 322-329)322. Interpretation (Chapter 1).323. Capital allowances in relation to construction of certain commercial premises.324. Double rent allowance in respect of rent paid for certain business premises.325. Rented residential accommodation: deduction for certain expenditure on construction.326. Rented residential accommodation: deduction for certain expenditure on conversion.327. Rented residential accommodation: deduction for certain expenditure on refurbishment.328. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.329. Provisions supplementary to sections 325 to 328.Chapter 2 Temple Bar Area (ss. 330-338)330. Interpretation (Chapter 2).331. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.332. Capital allowances in relation to construction or refurbishment of certain commercial premises.333. Double rent allowance in respect of rent paid for certain business premises.334. Rented residential accommodation: deduction for certain expenditure on construction.335. Rented residential accommodation: deduction for certain expenditure on conversion.336. Rented residential accommodation: deduction for certain expenditure on refurbishment.337. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.338. Provisions supplementary to sections 334 to 337.Chapter 3 Designated areas, designated streets, enterprise areas and multi-storey car parks in certain urban areas (ss. 339-350A)339. Interpretation (Chapter 3).340. Designated areas, designated streets and enterprise areas.341. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.342. Capital allowances in relation to construction or refurbishment of certain commercial premises.343. Capital allowances in relation to construction or refurbishment of certain buildings or structures in enterprise areas.344. Capital allowances in relation to construction or refurbishment of certain multi-storey car parks.345. Double rent allowance in respect of rent paid for certain business premises.346. Rented residential accommodation: deduction for certain expenditure on construction.347. Rented residential accommodation: deduction for certain expenditure on conversion.348. Rented residential accommodation: deduction for certain expenditure on refurbishment.349. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.350. Provisions supplementary to sections 346 to 349.350A. Provision against double relief.Chapter 4 Qualifying resort areas (ss. 351-359)351. Interpretation (Chapter 4).352. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.353. Capital allowances in relation to construction or refurbishment of certain commercial premises.354. Double rent allowance in respect of rent paid for certain business premises.355. Disclaimer of capital allowances on holiday cottages, holiday apartments, etc.356. Rented residential accommodation: deduction for certain expenditure on construction.357. Rented residential accommodation: deduction for certain expenditure on conversion.358. Rented residential accommodation: deduction for certain expenditure on refurbishment.359. Provisions supplementary to sections 356 to 358.Chapter 5 Designated islands (ss. 360-365)360. Interpretation (Chapter 5).361. Rented residential accommodation: deduction for certain expenditure on construction.362. Rented residential accommodation: deduction for certain expenditure on conversion.363. Rented residential accommodation: deduction for certain expenditure on refurbishment.364. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.365. Provisions supplementary to sections 360 to 364.Chapter 6 Dublin Docklands Area (ss. 366-372)366. Interpretation (Chapter 6).367. Qualifying areas.368. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.369. Capital allowances in relation to construction or refurbishment of certain commercial premises.370. Double rent allowance in respect of rent paid for certain business premises.371. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.372. Provisions supplementary to section 371.Chapter 7 Qualifying areas (ss. 372A-372K)372A. Interpretation and application (Chapter 7).372B. Qualifying areas.372BA. Qualifying streets.372C. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.372D. Capital allowances in relation to construction or refurbishment of certain commercial premises.372E. Double rent allowance in respect of rent paid for certain business premises.372F. Rented residential accommodation: deduction for certain expenditure on construction.372G. Rented residential accommodation: deduction for certain expenditure on conversion.372H. Rented residential accommodation: deduction for certain expenditure on refurbishment.372I. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.372J. Provisions supplementary to sections 372F to 372I.372K. Non-application of relief in certain cases and provision against double relief.Chapter 8 Qualifying rural areas (ss. 372L-372T)372L. Interpretation (Chapter 8).372M. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.372N.Capital allowances in relation to construction or refurbishment of certain commercial buildings or structures.372O. Double rent allowance in respect of rent paid for certain business premises.372P. Rented residential accommodation: deduction for certain expenditure on construction.372Q. Rented residential accommodation: deduction for certain expenditure on conversion.372R. Rented residential accommodation: deduction for certain expenditure on refurbishment.372RA. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.372S. Provisions supplementary to sections 372P to 372R.372T. Non-application of relief in certain cases and provision against double relief.Chapter 9 Park and ride facilities and certain related developments (ss. 372U-372Z)372U. Interpretation (Chapter 9).372V. Capital allowances in relation to construction or refurbishment of certain park and ride facilities.372W. Capital allowances in relation to construction or refurbishment of certain commercial premises.372X. Rented residential accommodation: deduction for certain expenditure on construction.372Y. Residential accommodation: allowance to owner-occupiers in respect of certain expenditure on construction.372Z. Provisions supplementary to sections 372X and 372Y.Chapter 10 Designated areas of certain towns (ss. 372AA-372AJ)372AA. Interpretation and application (Chapter 10).372AB. Qualifying areas.372AC. Accelerated capital allowances in relation to construction or refurbishment of certain industrial buildings or structures.372AD. Capital allowances in relation to construction or refurbishment of certain commercial premises.372AE. Rented residential accommodation: deduction for certain expenditure on construction.372AF. Rented residential accommodation: deduction for certain expenditure on conversion.372AG. Rented residential accommodation: deduction for certain expenditure on refurbishment.372AH. Residential accommodation allowance to owner-occupiers in respect of certain expenditure on construction or refurbishment.372AI. Provisions supplementary to sections 372AE to 372AH.372AJ. Non-application of relief in certain cases and provision against double relief.Chapter 11 Reliefs for lessors and owner-occupiers in respect of expenditure incurred on the provision of certain residential accommodation (ss. 372AK-372AV)372AK. Interpretation (Chapter 11).372AL. Qualifying period.372AM. Grant of certain certificates and guidelines, qualifying and special qualifying premises.372AN. Eligible expenditure: lessors.372AO. Qualifying lease.372AP. Relief for lessors.372AQ. Qualifying expenditure: owner-occupiers.372AR. Relief for owner-occupiers.372AS. Determination of expenditure incurred in qualifying period, and date expenditure treated as incurred for relief purposes.372AT. Appeals.372AU. Saver for relief due, and for clawback of relief given under, old schemes.372AV. Continuity.Chapter 12 Mid-Shannon Corridor Tourism Infrastructure Investment Scheme (372AW-372AZ)372AW. Interpretation, applications for approval and certification.372AX. Accelerated capital allowances in relation to the construction or refurbishment of certain registered holiday camps.372AY. Capital allowances in relation to the construction or refurbishment of certain tourism infrastructure facilities.372AZ. Restrictions on relief, non-application of relief in certain cases and provision against double relief.Chapter 13 Living City Initiative (ss. 372AAA-372AAE)372AAA. Interpretation (Chapter 13).372AAB. Residential accommodation: allowance to owner-occupiers in respect of qualifying expenditure incurred on the conversion and refurbishment of Georgian houses.372AAC. Capital allowances in relation to conversion or refurbishment of certain commercial premises.372AAD. Residential accommodation: capital allowances to lessors in respect of eligible expenditure incurred on the conversion and refurbishment of relevant houses.372AAE. Capital allowances in relation to conversion or refurbishment of certain qualifying premises.Part 11 Capital Allowances and Expenses for Certain Road Vehicles (ss. 373-380)373. Interpretation (Part 11).374. Capital allowances for cars costing over certain amount.375. Limit on renewals allowance for cars.376. Restriction of deduction in respect of running expenses of cars.377. Limit on deductions, etc. for hiring cars.378. Cars: provisions as to hire-purchase, etc.379. Cars: provisions where hirer becomes owner.380. Provisions supplementary to sections 374 to 379.Part 11A Income Tax and Corporation Tax: Deduction for Expenditure on Construction, Conversion and Refurbishment of Certain Residential Accommodation for Certain Students (ss. 380A-380F)380A. Interpretation (Part 11A).380B. Rented residential accommodation: deduction for certain expenditure on construction.380C. Rented residential accommodation: deduction for certain expenditure on conversion.380D. Rented residential accommodation: deduction for certain expenditure on refurbishment.380E. Provisions supplementary to sections 380B to 380D.380F. Provision against double relief.Part 11B Income Tax and Corporation Tax: Deduction for Expenditure on Refurbishment of Certain Residential Accommodation (ss. 380G-380J)380G. Interpretation (Part 11B).380H. Rented residential accommodation: deduction for certain expenditure on refurbishment.380I. Provisions supplementary to section 380H.380J. Provision against double relief.Part 11C Emissions-based Limits on Capital Allowances and Expenses for Certain Road Vehicles (ss. 380K-380P)380K. Interpretation and general (Part 11C).380L. Emissions-based limits for certain cars.380M. Limit on deductions, etc. for hiring cars.380N. Cars: provisions as to hire-purchase, etc.380O. Cars: provisions where hirer becomes owner.380P. Provisions supplementary to sections 380L to 380O.Part 11D Income Tax and Corporation Tax: Reliefs for the Removal and Relocation of Certain Industrial Facilities (ss. 380Q-380X)380Q. Interpretation (Part 11D).380R. Relocation allowance.380S. Additional allowance for relocation expenditure.380T. Allowance for machinery or plant.380U. Allowances in respect of certain buildings.380V. Improvement.380W. Supplementary provisions.380X. Restrictions on relief - non-application of relief in certain cases.Part 12 Principal Provisions Relating to Loss Relief, Treatment of Certain Losses and Capital Allowances, and Group Relief (ss. 381-429)Chapter 1 Income tax: loss relief (ss. 381-390)381. Right to repayment of tax by reference to losses.381A. Restriction of loss relief in certain cases.381B. Restriction of loss relief - passive trades.381C. Restriction of loss relief - anti-avoidance.382. Right to carry forward losses to future years.383. Relief under Case IV for losses.384. Relief under Case V for losses.385. Terminal loss.386. Determination of terminal loss.387. Calculation of amount of profits or gains for purposes of terminal loss.388. Meaning of "permanently discontinued" for purposes of terminal loss.389. Determination of claim for terminal loss.390. Amount of assessment made under section 238 to be allowed as a loss for certain purposes.Chapter 2 Income tax: loss relief - treatment of capital allowances (ss. 391-395)391. Interpretation (Chapter 2).392. Option to treat capital allowances as creating or augmenting a loss.393. Extent to which capital allowances to be taken into account for purposes of section 392.394. Effect of giving relief under section 381 by reference to capital allowances.395. Relief affected by subsequent changes of law, etc.Chapter 2A Income tax: Covid-19 loss relief (ss. 395A-395C)395A. Right to carry-back losses sustained between 1 January 2020 and 31 December 2020.395B. Interim claim for carry-back of relevant losses and relevant allowances.395C. Limitation of relief for relevant losses and allowances.Chapter 3 Corporation tax: loss relief (ss. 396-401)396. Relief for trading losses other than terminal losses.396A. Relief for relevant trading losses.396B. Relief for certain trading losses on a value basis.396C. Relief from Corporation Tax for losses of participating institutions.396D. Accelerated loss relief for certain accounting periods.397. Relief for terminal loss in a trade.398. Computation of losses attributable to exemption of income from certain securities.399. Losses in transactions from which income would be chargeable under Case IV or V of Schedule D.400. Company reconstructions without change of ownership.401. Change in ownership of company: disallowance of trading losses.Chapter 4 Income tax and corporation tax: treatment of certain losses and certain capital allowances (ss. 402-409E)402. Foreign currency: tax treatment of capital allowances and trading losses of a company.403. Restriction on use of capital allowances for certain leased assets.404. Restriction on use of capital allowances for certain leased machinery or plant.405. Restriction on use of capital allowances on holiday cottages.406. Restriction on use of capital allowances on fixtures and fittings for furnished residential accommodation.407. Restriction on use of losses and capital allowances for qualifying shipping trade.408. Restriction on tax incentives on property investment.409. Capital allowances: room ownership schemes.409A. Income tax: restriction on use of capital allowances on certain industrial buildings and other premises.409B. Income tax: restriction on use of capital allowances on certain hotels, etc.409C. Income tax: restriction on use of losses on approved buildings.409D. Restriction of reliefs where individual is not actively participating in certain trades.409E. Income tax: ring-fence on use of certain capital allowances on certain industrial buildings and other premises.Chapter 4A Termination of carry forward of certain losses (ss. 409F-409H)409F. Interpretation and general (Chapter 4A).409G. Termination of capital allowances.409H. Restriction on use of capital allowances.Chapter 5 Group relief (ss. 410-429)410. Group payments.411. Surrender of relief between members of groups and consortia.412. Qualification for entitlement to group relief.413. Profits or assets available for distribution.414. Meaning of "the profit distribution".415. Meaning of "the notional winding up".416. Limited right to profits or assets.417. Diminished share of profits or assets.418. Beneficial percentage.419. The relevant accounting period, etc.420. Losses, etc. which may be surrendered by means of group relief.420A. Group relief: relevant losses and charges.420B. Group relief: Relief for certain losses on a value basis.420C. Group relief: relief for certain losses of non-resident companies.421. Relation of group relief to other relief.422. Corresponding accounting periods.423. Company joining or leaving group or consortium.424. Effect of arrangements for transfer of company to another group, etc.425. Leasing contracts: effect on claims for losses of company reconstructions.426. Partnerships involving companies: effect of arrangements for transferring relief.427. Information as to arrangements for transferring relief, etc.428. Exclusion of double allowances, etc.429. Claims and adjustments.Part 13 Close Companies (ss. 430-441)Chapter 1 Interpretation and general (ss. 430-435)430. Meaning of "close company".431. Certain companies with quoted shares not to be close companies.432. Meaning of "associated company" and "control".433. Meaning of "participator", "associate", "director" and "loan creditor".434. Distributions to be taken into account and meaning of "distributable income", "investment income", "estate income", etc.435. Information.Chapter 2 Additional matters to be treated as distributions, charges to tax in respect of certain loans and surcharges on certain undistributed income (ss. 436-441)436. Certain expenses for participators and associates.436A. Certain settlements made by close companies.437. Interest paid to directors and directors' associates.438. Loans to participators, etc.438A. Extension of section 438 to loans by companies controlled by close companies.439. Effect of release, etc. of debt in respect of loan under section 438.440. Surcharge on undistributed investment and estate income.441. Surcharge on undistributed income of service companies.Part 14 Taxation of Companies Engaged in Manufacturing Trades, Certain Trading Operations Carried on in Shannon Airport and Certain Trading Operations Carried on in the Custom House Docks Area (ss. 442-457)Chapter 1 Interpretation and general (ss. 442-447)442. Interpretation (Part 14).443. Meaning of "goods".444. Exclusion of mining and construction operations.445. Certain trading operations carried on in Shannon Airport.446. Certain trading operations carried on in Custom House Docks Area.447. Appeals.Chapter 2 Principal provisions (ss. 448-457)448. Relief from corporation tax.449. Credit for foreign tax not otherwise credited.450. Double taxation relief.451. Treatment of income and gains of certain trading operations carried on in Custom House Docks Area from investments held outside the State.452. Application of section 130 to certain interest.452A. Application of section 130 of this Act to certain non-yearly interest.453. Transactions between associated persons.454. Restriction of certain charges on income.455. Restriction of certain losses.456. Restriction of group relief.457. Application of section 448 where profits are charged to corporation tax at the reduced rate.Part 15 Personal Allowances and Reliefs and Certain Other Income Tax and Corporation Tax Reliefs (ss. 458-487)Chapter 1 Personal allowances and reliefs (ss. 458-480C)458. Deductions allowed in ascertaining taxable income and provisions relating to reductions in tax.459. General provisions relating to allowances, deductions and reliefs.460. Rate of tax at which repayments are to be made.461. Basic personal tax credit.461A. Additional tax credit for certain widowed persons.462. One-parent family tax credit.462A. Additional allowance for widowed parents and other single parents.462B. Single person child carer credit.463. Widowed parent tax credit.464. Age tax credit.465. Incapacitated child tax credit.466. Dependent relative tax credit.466A. Home carer tax credit.467. Employed person taking care of incapacitated individual.468. Blind person's tax credit.469. Relief for health expenses.470. Relief for insurance against expenses of illness.470A. Relief for premiums under qualifying long-term care policies.470B. Age-related relief for health insurance premiums.471. Relief for contributions to permanent health benefit schemes.472. Employee allowance.472A. Relief for the long-term unemployed.472AA. Relief for long-term unemployed starting a business.472AB. Earned income tax credit.472B. Seafarer allowance, etc.472BA. Fisher tax credit.472BB. Sea-going naval personnel credit.472C. Relief for trade union subscriptions.472D. Relief for key employees engaged in research and development activities.473. Allowance for rent paid by certain tenants.473A. Relief for fees paid for third level education, etc.473B. Rent tax credit.473C. Mortgage interest tax relief.474. Relief for fees paid to private colleges for full-time third level education.474A. Relief for fees paid to publicly funded colleges in the European Union for full-time third level education.475. Relief for fees paid for part-time third level education.475A. Relief for postgraduate fees.476. Relief for fees paid for training courses.477. Relief for service charges.477A. Relief for energy efficient works.477B. Home renovation incentive.477C. Help to Buy.478. Relief for payments made by certain persons in respect of alarm systems.478A. Stay and spend tax credit.479. Relief for new shares purchased on issue by employees.480. Relief for certain sums chargeable under Schedule E.480A. Relief on retirement for certain income of certain sportspersons.480B. Relief arising in special circumstances.480C. Residential premises rental income relief Chapter 2 Income tax and corporation tax: reliefs applicable to both (ss. 481-485B)481. Relief for investment in films.481A. Relief for investment in digital games.482. Relief for expenditure on significant buildings and gardens.483. Relief for certain gifts.484.Objectives of section 485, purposes for which its provisions are enacted and certain duty of Minister for Finance respecting those provisions' operation.485. Covid Restrictions Support Scheme.485A. Business Resumption Support Scheme.485A. Relief for gifts made to designated schools.485B. Relief for gifts to the Scientific and Technological Education (Investment) Fund.Chapter 2A Limitation on amount of certain reliefs used by certain high income individuals (ss. 485C-485G)485C. Interpretation (Chapter 2A).485D. Application (Chapter 2A).485E. Recalculation of taxable income for purposes of limiting reliefs.485F. Carry forward of excess relief.485FA. Adaptation of provisions relating to taxation of married persons.485FB. Requirement to provide estimates and information.485G. Miscellaneous (Chapter 2A).Chapter 3 Corporation tax reliefs (ss. 486-487A)486. Corporation tax: relief for gifts to First Step.486A. Corporate donations to eligible charities.486B. Relief for investment in renewable energy generation.486C. Relief from tax for certain start-up companies.487. Corporation tax: credit for bank levy.487A. Tax credit for expenditure on unscripted production Part 16 Relief for Investment in Corporate Trades (ss. 488-508Z)Chapter 1 Interpretation (Part 16) (s. 488)488. Interpretation (Part 16).Chapter 2 Qualifying companies (ss. 489-492)489. Interpretation (Chapter 2)490. Qualifying companies 491. Qualifying companies (supplemental)492. Qualifying subsidiaries Chapter 3 Qualifying investments (ss. 493-499)493. Interpretation (Chapter 3)494. Eligible shares 495. Anti-avoidance: eligible shares 496. Qualifying investment (company perspective)497. Limits on amounts a qualifying company can raise 498. Qualifying investment (investor perspective)499. Anti-avoidance: qualifying investment (investor perspective)Chapter 4 Employment investment incentive (ss. 500-503)500. Qualifying investors.501. Anti-avoidance: qualifying investors 502. The relief (Chapter 4)503. The relief: start-up capital incentive.Chapter 5 Start-up relief for entrepreneurs (SURE) (ss. 504-507)504. Interpretation (Chapter 5)505. Specified individuals.506. Anti-avoidance: qualifying company (SURE).507. The relief (Chapter 5).Chapter 6 Administrative requirements and reporting obligations (ss. 508-508G)508. Carry forward of unused relief 508A. Statement of qualification by qualifying company.508B. Statement of qualification (second stage relief) by qualifying company 508C. Statement of qualification (SURE) by qualifying company 508D. Confirmation of compliance with certain conditions 508E. Reporting of relief by qualifying companies 508F. Claims for relief by qualifying investors 508G. Claims for relief by specified individuals Chapter 7 Investment Funds (ss. 508H-508J)508H. Authorised officers 508I. Designated investment funds 508IA. Qualifying investment funds 508J. Relief for investment through designated investment funds Chapter 8 Capital gains tax implications (s. 508K)508K. Capital gains tax Chapter 9 Anti-avoidance (s. 508L)508L. Prevention of misuse Chapter 10 Clawback events (ss. 508M-508S)508M. Disposals of shares 508N. Anti-avoidance: disposal of shares 508O. Anti-avoidance: disposal of a qualifying subsidiary 508P. Anti-avoidance: qualifying investor receiving value from the company 508Q. Qualification to section 508P for specified persons 508R. Value received by persons other than qualifying investors 508S. Failure to commence a relevant employment (relief under section 508G)Chapter 11 Withdrawing relief (ss. 508T-508Y)508T. Withdrawing relief - general 508U. Assessments for withdrawing relief claimed under Chapter 4 - company.508V. Assessments for withdrawing relief under Chapter 4 - investor 508W. Assessments for withdrawing relief under Chapter 5 508X. Treatment of statement of qualification as a return 508Y. Information Chapter 12 Application of this Part (s. 508Z)508Z. Application of this Part Part 17 Profit Sharing Schemes and Employee Share Ownership Trusts (ss. 509-519D)Chapter 1 Profit sharing schemes (ss. 509-518)509. Interpretation (Chapter 1).510. Approved profit sharing schemes: appropriated shares.511. The period of retention, release date and appropriate percentage.511A. Shares acquired from an employee share ownership trust.512. Disposals of scheme shares.513. Capital receipts in respect of scheme shares.514. Company reconstructions, amalgamations, etc.515. Excess or unauthorised shares.516. Assessment of trustees in respect of sums received.517. Payments to trustees of approved profit sharing scheme.518. Costs of establishing profit sharing schemes.Chapter 2 Employee share ownership trusts (s. 519)519. Employee share ownership trusts.Chapter 3 Savings-related share option schemes (ss. 519A-519C)519A. Approved savings-related share option schemes.519B. Costs of establishing savings-related share option schemes.519C. Interest, etc. under certified contractual savings schemes.Chapter 4 Approved Share Option Schemes (s. 519D)519D. Approved Share Option Schemes.Part 18 Payments in Respect of Professional Services by Certain Persons and Payments to Subcontractors in Certain Industries (ss. 520-531)Chapter 1 Payments in respect of professional services by certain persons (ss. 520-529A)520. Interpretation (Chapter 1).521. Accountable persons.522. Obligation on authorised insurers.523. Deduction of tax from relevant payments.524. Identification of specified persons and submission of payment notifications.525. Returns and collection of appropriate tax.526. Credit for appropriate tax borne.527. Interim refunds of appropriate tax.528. Apportionment of credits or interim refunds of appropriate tax.529. Limitation on credits or interim refunds of appropriate tax.529A. Partnerships.Chapter 1A Payments in respect of non-resident artistes by companies qualifying for relief for investment in films (ss. 529B-529M)529B. Interpretation (Chapter 1A)529C. Deduction of tax from relevant payments 529D. Identification of, and issue of documents to, specified persons 529E. Returns by qualifying company 529F. Payment of tax by qualifying company 529G. Assessment by Revenue officer 529H. Interest on late payment of appropriate tax 529I. Repayment of appropriate tax 529J. Obligation on specified person 529K. Record keeping and inspection of records 529L. Civil penalties 529M. Miscellaneous Chapter 2 Payments to subcontractors in certain industries (ss. 530-531)530. Interpretation (Chapter 2).530A. Principal to whom relevant contracts tax applies.530B. Notification of contract by principal.530C. Notification of relevant payment by principal.530D. Deduction authorisation.530E. Rates of tax.530F. Obligation on principals to deduct tax.530G. Zero rate subcontractor.530H. Standard rate subcontractor.530I. Determination of rates.530J. Register of principals.530K. Return by principal.530L. Payment of tax by principal.530M. Late returns and amendments.530N. Assessment by Revenue officer.530O. Computation of subcontractor's profit.530P. Treatment of deducted tax.530Q. Interest.530R. Partnerships.530S. Record keeping.530T. Inspection of records.530U. Civil penalties.530V. Miscellaneous.531. Payments to subcontractors in certain industries.Levies (ss. 531A-531AAQ)Part 18A Income Levy (ss. 531A-531NA)531A. Definitions (Part 18A).531B. Charge to income levy.531C. Rate of charge.531D. Deduction and payment of income levy on relevant emoluments.531E. Record keeping.531F. Power of inspection.531G. Estimation of income levy due for income tax months and for year.531H. Assessment, collection, payment and recovery of income levy on aggregate income for the year of assessment.531I. Married couples.531J. False statements.531K. Repayments.531L. Restriction on deduction.531M. Application of provisions relating to income tax.531N. Care and management.531NA. Cessation of charge to income levy.Part 18B Parking Levy in Urban Areas (ss. 531O-531Z)531O. Interpretation (Part 18B).531P. Urban areas to which parking levy applies and making of orders by the Minister.531Q. Entitlement to use a parking space.531R. Provision of parking space by employer.531S. Exemption for certain persons.531T. Charge to parking levy.531U. Rate of charge to parking levy.531V. Deduction of levy by employer.531W. No relief for any payment in relation to parking levy.531X. Records and regulations.531Y. Payment, collection and recovery.531Z. Penalties.Part 18C Domicile Levy (ss. 531AA-531AK)531AA. Interpretation (Part 18C).531AB. Charge to domicile levy.531AC. Credit for income tax paid.531AD. Valuation procedures.531AE. Appeals regarding value of real property.531AF. Delivery of returns.531AG. Opinion of Revenue Commissioners.531AH. Making and amending of assessments by Revenue Commissioners.531AI. Right of Revenue Commissioners to make enquiries and amend assessments.531AJ. Application of provisions relating to income tax.531AK. Care and management.Part 18D Universal Social Charge (ss. 531AL-531AAF)531AL. Definitions (Part 18D).531AM. Charge to universal social charge.531AN. Rate of charge.531AO. Deduction and payment of universal social charge on relevant emoluments.531AOA. Return by employer.531AP. Record keeping.531AQ. Power of inspection.531AR. Estimation of universal social charge due.531AS. Universal social charge payable by chargeable persons (within the meaning of Part 41).531AT. Universal social charge payable by persons other than chargeable persons (within the meaning of Part 41).531AU. Capital allowances and losses.531AUA. Universal social charge and approved profit sharing schemes.531AV. Married couples.531AW. Repayments.531AX. Restriction on deduction.531AY. Recovery of unpaid universal social charge.531AZ. Repayments of, and recovery of unpaid, income levy.531AAA. Application of provisions relating to income tax.531AAB. Regulations.531AAC. Care and management.531AAD. Excess bank remuneration charge.531AAE. Property relief surcharge.531AAF. Delegation of functions and discharge of functions by electronic means.Part 18E Defective Concrete Products Levy (ss. 531AAG-531AAQ)531AAG. Interpretation (Part 18E).531AAH. Charging of defective concrete products levy 531AAI. Amount of defective concrete products levy 531AAJ. Obligation to register 531AAJA. First supply of ready to pour concrete to specified person.531AAJB. Repayment of defective concrete products levy.531AAK. Returns and payments by chargeable persons.531AAL. Assessments, enquiries and appeals 531AAM. Interest on overdue defective concrete products levy.531AAN. Obligation to keep certain records.531AAO. Care and management of defective concrete products levy 531AAP. Valuation procedures 531AAQ. Application of Part 18E Taxation of Chargeable Gains (ss. 532-638)Part 19 Principal Provisions Relating to Taxation of Chargeable Gains (ss. 532-613A)Chapter 1 Assets and acquisitions and disposals of assets (ss. 532-543)532. Assets.533. Location of assets.534. Disposals of assets.535. Disposals where capital sums derived from assets.536. Capital sums: receipt of compensation and insurance moneys not treated as a disposal in certain cases.537. Mortgages and charges not to be treated as disposals.538. Disposals where assets lost or destroyed or become of negligible value.539. Disposals in cases of hire purchase and similar transactions.540. Options and forfeited deposits.540A. Disposal of certain emissions allowances.541. Debts.541A. Treatment of debts on a change in currency.541B. Restrictive covenants.541C. Tax treatment of certain venture fund managers.542. Time of disposal and acquisition.543. Transfers of value derived from assets.Chapter 2 Computation of chargeable gains and allowable losses (ss. 544-566)544. Interpretation and general (Chapter 2).545. Chargeable gains.545A. Share disposals and central securities depositories 546. Allowable losses.546A. Restrictions on allowable losses.547. Disposals and acquisitions treated as made at market value.548. Valuation of assets.549. Transactions between connected persons.550. Assets disposed of in series of transactions.551. Exclusion from consideration for disposals of sums chargeable to income tax.552. Acquisition, enhancement and disposal costs.553. Interest charged to capital.554. Exclusion of expenditure by reference to income tax.555. Restriction of losses by reference to capital allowances and renewals allowances.556. Adjustment of allowable expenditure by reference to consumer price index.557. Part disposals.558. Part disposals before 6th day of April, 1978.559. Assets derived from other assets.560. Wasting assets.561. Wasting assets qualifying for capital allowances.562. Contingent liabilities.563. Consideration due after time of disposal.564. Woodlands.565. Expenditure reimbursed out of public money.566. Leases.Chapter 3 Assets held in a fiduciary or representative capacity, inheritances and settlements (ss. 567-579F)567. Nominees, bare trustees and agents.568. Liability of trustees, etc.569. Assets of insolvent person.570. Company in liquidation.571. Chargeable gains accruing on disposals by liquidators and certain other persons.572. Funds in court.573. Death.574. Trustees of settlement.575. Gifts in settlement.576. Person becoming absolutely entitled to settled property.577. Termination of life interest on death of person entitled.577A. Relinquishing of a life interest by the person entitled.578. Death of annuitant.579. Non-resident trusts.579A. Attribution of gains to beneficiaries.579B. Trustees ceasing to be resident in the State.579C. Death of trustee: special rules.579D. Past trustees: liability for tax.579E. Trustees ceasing to be liable to Irish tax.579F. Migrant settlements.Chapter 4 Shares and securities (ss. 580-592)580. Shares, securities, etc: identification.581. Disposals of shares or securities within 4 weeks of acquisition.582. Calls on shares.583. Capital distributions by companies.584. Reorganisation or reduction of share capital.585. Conversion of securities.586. Company amalgamations by exchange of shares.587. Company reconstructions and amalgamations.588. Demutualisation of assurance companies.589. Shares in close company transferring assets at undervalue.590. Attribution to participators of chargeable gains accruing to non-resident company.591. Relief for individuals on certain reinvestment.591A. Dividends paid in connection with disposals of shares or securities.592. Reduced rate of capital gains tax on certain disposals of shares by individuals.Chapter 5 Life assurance and deferred annuities (ss. 593-595)593. Life assurance and deferred annuities.594. Foreign life assurance and deferred annuities: taxation and returns.595. Life assurance policy or deferred annuity contract entered into or acquired by company.Chapter 6 Transfer of business assets (ss. 596-600A)596. Appropriations to and from stock in trade.597. Replacement of business and other assets.597A. Entrepreneur relief.597AA. Revised entrepreneur relief 598. Disposals of business or farm on "retirement".598A. Relief on dissolution of farming partnerships.599. Disposals within family of business or farm.600. Transfer of business to company.600A. Replacement of qualifying premises.Chapter 6A Relief for investment in innovative enterprises (ss. 600B-600S)600B. Interpretation.600C. Qualifying company.600D. Qualifying subsidiary.600E. Qualifying investment (company perspective).600F. Certificates of qualification.600G. Subscription for shares.600H. Qualifying investor.600I. Anti-avoidance: qualifying investor.600J. Qualifying investment (investor perspective).600K. Anti-avoidance: qualifying investment (shares).600L. Anti-avoidance: qualifying investment (investor perspective).600M. Relief.600N. Qualifying partnership.600O. Interaction of relief with other provisions of this Act.600P. Failure to comply with requirements of this Chapter.600Q. Powers.600R. Application of the Chapter.600S. Reporting of relief by qualifying companies.Chapter 7 Other reliefs and exemptions (ss. 601-613A)601. Annual exempt amount.602. Chattel exemption.603. Wasting chattels.603A. Disposal of site to child.604. Disposals of principal private residence.604A. Relief for certain disposals of land or buildings.604B. Relief for farm restructuring.604C. Exemption of certain payment entitlements.605. Disposals to authority possessing compulsory purchase powers.606. Disposals of work of art, etc., loaned for public display.607. Government and certain other securities.608. Superannuation funds.609. Charities.610. Other bodies.610A. Exemption for proceeds of disposal by sports bodies.611. Disposals to State, public bodies and charities.611A. Treatment of certain disposals made by The Pharmaceutical Society of Ireland.612. Scheme for retirement of farmers.613. Miscellaneous exemptions for certain kinds of property.613A. Supplementary provisions.Part 20 Companies' Chargeable Gains (ss. 614-629C)Chapter 1 General (ss. 614-626C)614. Capital distribution derived from chargeable gain of company: recovery of tax from shareholder.615. Company reconstruction or amalgamation: transfer of assets.616. Groups of companies: interpretation.617. Transfers of assets, other than trading stock, within group.617A. Transfers arising from certain mergers under Companies Act 2014.618. Transfers of trading stock within group.619. Disposals or acquisitions outside group.620. Replacement of business assets by members of group.620A. Deemed disposal in certain circumstances.621. Depreciatory transactions in group.622. Dividend stripping.623. Company ceasing to be member of group.623A. Transitional provisions in respect of section 623.624. Exemption from charge under section 623 in case of certain mergers.625. Shares in subsidiary member of group.625A. Transitional provisions in respect of section 625.626. Tax on company recoverable from other members of group.626A. Restriction on set-off of pre-entry losses.626B. Exemption from tax in the case of gains on certain disposals of shares.626C. Treatment of assets related to shares.Chapter 2 Provisions relating to exit tax, etc. (ss. 627-629C)627. Charge to exit tax 628. Value of certain assets to be accepted for purposes of Capital Gains Tax Acts 628A. Deferral of exit tax. [Substituted with new Chapter 2]629. Deferral of exit tax 629A. Tax on non-resident company recoverable from another member of group or from controlling director 629B. Transitional provision (power to serve notice under former section 629 not affected)629C. Company ceasing to be resident on formation of SE or SCE Part 21 Provisions Relating to Mergers, Divisions and Transfers of Assets (ss. 630-638A)Chapter 1 Mergers, divisions, transfers of assets and exchanges of shares concerning companies of different Member States (ss. 630-638)630. Interpretation (Part 21).631. Transfer of assets generally.632. Transfer of assets by company to its parent company.633. Company reconstruction or amalgamation: transfer of development land.633A. Formation of SE or SCE by merger - leaving assets in the State.633B. Formation of SE or SCE by merger - not leaving assets in the State.633C. Treatment of securities on a merger.633D. Mergers where a company is dissolved without going into liquidation.634. Credit for tax.635. Avoidance of tax.636. Returns.637. Other transactions.638. Apportionment of amounts.Chapter 2 Mergers and divisions pursuant to Companies Act 2014 (s. 638A)638A. Company mergers and divisions Transactions in Land (ss. 639-653BO)Part 22 Provisions Relating to Dealing In or Developing Land and Disposals of Development Land (ss. 639-653)Chapter 1 Income tax and corporation tax: profits or gains from dealing in or developing land (ss. 639-647)639. Interpretation (Chapter 1).640. Extension of charge under Case I of Schedule D to certain profits from dealing in or developing land.641. Computation under Case I of Schedule D of profits or gains from dealing in or developing land.642. Transfers of interests in land between certain associated persons.643. Tax to be charged under Case IV on gains from certain disposals of land.644. Provisions supplementary to section 643.644A. Relief from income tax in respect of income from dealing in residential development land.644AA. Treatment of losses from dealing in residential development land.644AB. Treatment of profits or gains from land rezonings.644B. Relief from corporation tax in respect of income from dealing in residential development land.644C. Relief from corporation tax for losses from dealing in residential development land.645. Power to obtain information.646. Postponement of payment of income tax to be permitted in certain cases.647. Postponement of payment of corporation tax to be permitted in certain cases.Chapter 2 Capital gains tax: disposals of development land (ss. 648-653)648. Interpretation (Chapter 2).649. Companies chargeable to capital gains tax in respect of chargeable gains accruing on relevant disposals.649A. Relevant disposals: rate of charge.649B. Windfall gains from rezonings: rate of charge.650. Exclusion of certain disposals.651. Restriction of indexation relief in relation to relevant disposals.652. Non-application of reliefs on replacement of assets in case of relevant disposals.653. Restriction of relief for losses, etc. in relation to relevant disposals.Part 22A Residential zoned land tax (ss. 653A-653AMA)Chapter 1 Interpretation (s. 653A)653A. Interpretation.Chapter 2 Zoned serviced residential development land (ss. 653B-653P)653B. Criteria for inclusion in map.653C. Draft map - preparation.653D. Draft map - submissions.653E. Draft map - determinations on exclusions and date.653F. Supplemental map - preparation.653G. Supplemental map-submissions.653H. Supplemental map - determinations on exclusions and date.653I. Zoning submissions.653IA. Exemption on submission of request for change to zoning of land included on revised map for the year 2025.653J. Appeal.653K. Final map.653L. Effect of appeal or judicial review.653M. Revision of final maps.653N. Receipt of information by Revenue Commissioners.653O. Relevant site.653P. Liable persons.Chapter 3 Residential zoned land tax (ss. 653Q-635R)653Q. Charge to residential zoned land tax.653R. Amount of residential zoned land tax.Chapter 4 Pay and file obligations (ss. 635S-653AC)653S. Obligation to register.653T. Obligation on liable person to prepare and deliver return.653U. One return in respect of jointly owned relevant site.653V. Designated liable person.653W. Preparation and delivery of return by person acting under authority.653X. Assessments, enquiries and appeals.653Y. Interest on overdue tax.653Z. Transfer of relevant site.653AA. Appointment of an expert.653AB. Surcharge for undervaluation of the relevant site.653AC. Surcharge for late return of the relevant site.Chapter 5 Abatements (ss. 653AD-653AHA)653AD. Repayment of tax on site not suitable for development.653AE. Deferral of tax on appeals under section 653J.653AF. Deferral of tax during appeals.653AFA. Deferral of tax during application to retain unauthorised development or for substitute consent 653AFB.Deferral of tax during appeals in respect of applications to retain unauthorised development or for substitute consent.653AG. Sites developed wholly or partly for purpose other than residential development.653AGA. Deferral of residential zoned land tax in respect of grant of planning permission 653AH. Deferral of residential zoned land tax in certain circumstances.653AHA. Sites subject to a relevant contract Chapter 6 Death cases (s. 653AI)653AI. Death.Chapter 7 Miscellaneous (ss. 653AJ-653AMA)653AJ. Obligation to keep certain records.653AK. Restriction of deduction.653AL. Care and management of residential zoned land tax.653AM. Where no owner registered.653AMA. Functions conferred on Limerick City and County Council.Part 22B Vacant Homes Tax (ss. 653AN-653BO)Chapter 1 Interpretation (s. 653AN)653AN. Interpretation Chapter 2 Vacant homes tax (ss. 653AO-653AP)653AO. Charge to vacant homes tax 653AP. Amount of vacant homes tax Chapter 3 Obligations on chargeable persons (ss. 653AQ-653BB)653AQ. Obligation on chargeable person to prepare and deliver a return 653AR. One return in respect of jointly owned property 653AS. Designated chargeable person 653AT. Company returns 653AU. Preparation and delivery of return by person acting under authority 653AV. Self-assessment and signed declaration 653AW. Electronic delivery of returns 653AX. Date for delivery of returns 653AY. Date for payment of vacant homes tax 653AZ. Requirement to prepare and deliver return where payment arrangement in place 653BA. Retention of records 653BB. Notice to provide records Chapter 4 Exemptions (s. 653BC)653BC. Exemptions Chapter 5 Assessments, enquiries and appeals (s. 653BD)653BD. Assessments, enquiries and appeals Chapter 6 Interest on overdue tax, surcharge for late filing and penalties (ss. 653BE-653BG)653BE. Interest on overdue tax 653BF. Surcharge for late filing of vacant homes tax return 653BG. Penalties Chapter 7 Management provisions(ss. 653BH-653BL)653BH. Care and management 653BI. Power to combine forms 653BJ. Power to require return of property 653BK. Revenue Commissioners may decide on allocation of payment 653BL. Register Chapter 8 Miscellaneous provisions (ss. 653BM-653BO)653BM. Information to be provided to Revenue Commissioners 653BN. Information to be provided by Revenue Commissioners 653BO. Restriction of deduction Other Special Provisions (ss. 654-848AG)Part 23 Farming and Market Gardening (ss. 654-669O)Chapter 1 Interpretation and general (ss. 654-664A)654. Interpretation (Part 23).654A. Trained farmer qualifications 655. Farming and market gardening profits to be charged to tax under Schedule D.656. Farming: trading stock of discontinued trade.657. Averaging of farm profits.657A. Taxation of certain farm payments.657B. Restructuring and diversification aid for sugar beet growers.658. Farming: allowances for capital expenditure on construction of buildings and other works.658A. Farming: accelerated allowances for capital expenditure on slurry storage.659. Farming: allowances for capital expenditure on the construction of farm buildings, etc. for control of pollution.660. Farming: wear and tear allowances deemed to have been made in certain cases.661. Farming: restriction of relief in respect of certain losses.662. Income tax: restriction of relief for losses in farming or market gardening.663. Corporation tax: restriction of relief for losses in farming or market gardening.664. Relief for certain income from leasing of farm land.664A. Relief for increase in carbon tax on farm diesel.Chapter 2 Farming: relief for increase in stock values (ss. 665-669)665. Interpretation (Chapter 2).666. Deduction for increase in stock values.667. Special provisions for qualifying farmers.667A. Further provisions for qualifying farmers.667B. New arrangements for qualifying farmers.667C. Special provisions for registered farm partnerships.667D. Succession farm partnerships 667E. Authorised officers 667F. Appeals officer 667G. Appeals 668. Compulsory disposals of livestock.669. Supplementary provisions (Chapter 2).Chapter 3 Milk Quotas (ss. 669A-669F)669A. Interpretation.669B. Annual allowances for capital expenditure on purchase of milk quota.669C. Effect of sale of quota.669D. Manner of making allowances and charges.669E. Application of Chapter 4 of Part 9.669F. Commencement (Chapter 3).Chapter 4 Taxation of stallion profits and gains (ss. 669G-669K)669G. Interpretation (Chapter 4).669H. Charging provisions.669I. Provisions as to deductions.669J. Credit for tax paid.669K. Miscellaneous (Chapter 4).Chapter 5 Tax treatment of certain payments to holders of sea-fishing boat licences (ss. 669L-669O)669L. Definitions 669M. Exemption for licence holder in respect of certain crew payments 669N. Balancing charges on relevant vessel 669O. Exemption in respect of the catch sum Part 24 Taxation of Profits of Certain Mines and Petroleum Taxation (ss. 670-696M)Chapter 1 Taxation of profits of certain mines (ss. 670-683)670. Mine development allowance.671. Marginal coal mine allowance.672. Interpretation (sections 672 to 683).673. Allowance in respect of development expenditure and exploration expenditure.674. Expenditure on abortive exploration.675. Exploration expenditure incurred by certain bodies corporate.676. Expenditure incurred by person not engaged in trade of mining.677. Investment allowance in respect of exploration expenditure.678. Allowance for machinery and plant.679. Exploration expenditure.680. Annual allowance for mineral depletion.681. Allowance for mine rehabilitation expenditure.682. Marginal mine allowance.683. Charge to tax on sums received from sale of scheduled mineral assets.Chapter 2 Petroleum taxation (ss. 684-696A)684. Interpretation (Chapter 2).685. Separation of trading activities.686. Reduction of corporation tax.687. Treatment of losses.688. Treatment of group relief.689. Restriction of relief for losses on certain disposals.690. Interest and charges on income.691. Restriction of set-off of advance corporation tax.692. Development expenditure: allowances and charges.693. Exploration expenditure: allowances and charges.694. Exploration expenditure incurred by certain companies.695. Abandonment expenditure: allowances and loss relief.696. Valuation of petroleum in certain circumstances.696A. Treatment of certain disposals.Chapter 3 Profit Resource Rent Tax (ss. 696B-696F)696B. Interpretation and application (Chapter 3).696C. Charge to profit resource rent tax.696D. Provisions relating to groups (Chapter 3).696E. Returns (Chapter3).696F. Collection and general provisions.Chapter 4 Petroleum production tax (ss. 696G-696M)696G. Interpretation and application (Chapter 4)696H. Charge to petroleum production tax 696I. Petroleum production tax and corporation tax 696J. Provisions relating to groups 696K. Returns 696L. Payment of tax 696M. Collection and general provisions Part 24A Shipping: Tonnage Tax (ss. 697A-697Q)697A. Interpretation (Part 24A).697B. Application.697C. Calculation of profits of tonnage tax company.697D. Election for tonnage tax.697E. Requirement that not more than 75 per cent of fleet tonnage is chartered in.697F. Requirement not to enter into tax avoidance arrangements.697G. Appeals.697H. Relevant shipping income: distributions of overseas shipping companies.697I. Relevant shipping income: cargo and passengers.697J. Relevant shipping income: foreign currency gains.697K. General exclusion of investment income.697L. Tonnage tax trade.697LA. Transactions between associated persons and between tonnage tax trade and other activities of same company.697LB. Treatment of finance costs.697M. Exclusion of reliefs, deductions and set-offs.697N. Chargeable gains.697O. Capital allowances: general.697P. Withdrawal of relief etc. on company leaving tonnage tax.697Q. Ten year disqualification from re-entry into tonnage tax.Part 24B Council Regulation (EU) 2022/1854 of 6 October 2022[OJ L 261, 7.10.2022, p.1] as regards temporary solidarity contribution (ss. 697R-697U)697R. Interpretation 697S. Taxable profits for purposes of temporary solidarity contribution 697T. Average taxable profits for purposes of temporary solidarity contribution 697U. Deductibility of temporary solidarity contribution for corporation tax Part 25 Industrial and Provident Societies, Building Societies, and Trustee Savings Banks (ss. 698-705)Chapter 1 Industrial and provident societies (ss. 698-701)698. Interpretation (Chapter 1).699. Deduction as expenses of certain sums, etc.700. Special computational provisions.701. Transfer of shares held by certain societies to members of society.Chapter 2 Building societies (ss. 702-703)702. Union or amalgamation of, transfer of engagement between, societies.703. Change of status of society.Chapter 3 Trustee savings banks (ss. 704-705)704. Amalgamation of trustee savings banks.705. Reorganisation of trustee savings banks into companies.Part 25A Real Estate Investment Trusts (ss. 705A-705Q)705A. Interpretation and application.705B. Conditions for notice under section 705E.705C. Conditions regarding shares.705D. Conditions regarding an accounting period.705E. Notice to become a Real Estate Investment Trust.705F. Duration of Real Estate Investment Trust.705G. Charge to tax.705H. Profit: financing cost ratio.705HA. Profit: calculating profits available for distribution.705I. Funds awaiting reinvestment.705IA. Disposals and reinvestments.705J. Taxation of shareholders.705K. Taxation of certain shareholders.705L. Transfer of assets.705M. Annual statement to Revenue.705N. Breach of conditions regarding distributions.705O. Cessation Notice.705P. Effect of cessation.705Q. Anti-avoidance provision.Part 26 Life Assurance Companies (ss. 706-730K)Chapter 1 General provisions (ss. 706-722)706. Interpretation and general (Part 26).707. Management expenses.708. Acquisition expenses.709. Companies carrying on life business.710. Profits of life business.711. Chargeable gains of life business.712. Distributions received from Irish resident companies.713. Investment income reserved for policyholders.714. Life business: computation of profits.715. Annuity business: separate charge on profits.716. General annuity business.717. Pension business.718. Foreign life assurance funds.719. Deemed disposal and reacquisition of certain assets.720. Gains or losses arising by virtue of section 719.721. Life policies carrying rights not in money.722. Benefits from life policies issued before 6th April, 1974.Chapter 2 Special investment policies (ss. 723-725)723. Special investment policies.724. Transfer of assets into or out of special investment fund.725. Special investment policies: breaches of conditions.Chapter 3 Provisions applying to overseas life assurance companies (ss. 726-730)726. Investment income.727. General annuity and pension business.728. Expenses of management.729. Income tax, foreign tax and tax credit.730. Tax credit in respect of distributions.Chapter 4 Taxation of assurance companies - new basis (s. 730A)730A. Profits of life business: new basis.Chapter 5 Policyholders - New basis (ss. 730B-730GB)730B. Taxation of policyholders.730BA. Personal portfolio life policy.730C. Chargeable event.730D. Gain arising on a chargeable event.730E. Declarations.730F. Deduction of tax on the happening of a chargeable event.730FA. Assessment of appropriate tax where tax not deducted under section 730F.730G. Returns and collection of appropriate tax.730GA. Repayment of appropriate tax.730GB. Capital acquisitions tax: set-off.Chapter 6 Certain Foreign Life Policies - Taxation and Returns (ss. 730H-730K)730H. Interpretation and application.730I. Returns on acquisition of foreign life policy.730J. Payment in respect of foreign life policy.730K. Disposal of foreign life policy.Part 27 Unit Trusts and Offshore Funds (ss. 731-747G)Chapter 1 Unit trusts (ss. 731-739A)731. Chargeable gains accruing to unit trusts.732. Special arrangements for qualifying unit trusts.733. Reorganisation of units in unit trust scheme.734. Taxation of collective investment undertakings.735. Certain unit trusts not to be collective investment undertakings.736. Option for non-application of section 735.737. Special investment schemes.738. Undertakings for collective investment.739. Taxation of unit holders in undertakings for collective investment.739A. Reorganisation of undertakings for collective investment.Chapter 1A Investment Undertakings (ss. 739B-739J)739B. Interpretation and application.739BA. Personal portfolio investment undertaking.739C. Charge to tax.739D. Gain arising on a chargeable event.739E. Deduction of tax on the occurrence of a chargeable event.739F. Returns and collection of appropriate tax.739FA. Electronic account filing requirement 739G. Taxation of unit holders in investment undertakings.739H. Investment undertakings: reconstructions and amalgamations.739HA. Investment undertakings: amalgamations with offshore funds.739I. Common contractual funds.739J. Investment limited partnerships.Chapter 1B Irish real estate funds (ss. 739K-739X)739K. Interpretation.739KA. Associated enterprises.739L. Calculating the IREF taxable amount.739LA. Profit: financing cost ratio.739LAA. Profit: financing cost ratio from 1 January 2020.739LB. Profit: calculating profits available for distribution.739LC. Exclusion for third-party debt.739M. Anti-avoidance: multiple funds.739N. Anti-avoidance: multiple funds further measures.739O. Tax arising on IREF taxable event.739P. Withholding tax arising on IREF taxable event.739Q. Repayment of IREF withholding tax.739QA. Advance clearance procedures for indirect investors in respect of withholding tax 739QB. Advance clearance procedures for direct investors in respect of withholding tax 739R. Returns, payment and collection of IREF withholding tax.739S. Statement to be given to recipients on the making of an IREF relevant payment.739T. Deduction from consideration on the disposal of certain units.739U. Retention and examination of documentation.739V. Transfer of IREF business to a company.739W. Transfer of IREF business to a REIT.739X. Application of this Chapter.Chapter 2 Offshore funds (ss. 740-747)740. Interpretation (Chapter 2 and Schedules 19 and 20).741. Disposals of material interests in non-qualifying offshore funds.742. Offshore funds operating equalisation arrangements.743. Material interest in offshore funds.744. Non-qualifying offshore funds.745. Charge to income tax or corporation tax of offshore income gain.746. Offshore income gains accruing to persons resident or domiciled abroad.747. Deduction of offshore income gain in determining capital gain.Chapter 3 Offshore funds: supplementary provisions (ss. 747A-747AA)747A. Capital gains tax: rate of charge.747AA. Treatment of certain offshore funds.Chapter 4 Certain Offshore Funds - Taxation and Returns (ss. 747B-747FA)747B. Interpretation and application.747C. Return on acquisition of material interest.747D. Payment in respect of offshore funds.747E. Disposal of an interest in offshore funds.747F. Reconstructions and amalgamations in offshore funds.747FA. Offshore funds: amalgamations with investment undertakings.Chapter 5 Relevant UCITS and Relevant AIF (s. 747G)747G. Tax treatment of a relevant UCITS or a relevant AIF.Part 28 Purchase and Sale of Securities (ss. 748-753F)Chapter 1 Purchase and sale of securities (ss. 748-751B)748. Interpretation and application (Chapter 1).749. Dealers in securities.750. Persons entitled to exemption.751. Traders other than dealers in securities.751A. Exchange of shares held as trading stock.751B. Exchange of Irish Government bonds.Chapter 2 Purchases of shares by financial concerns and persons exempted from tax, and restriction on relief for losses by repayment of tax in case of dividends paid out of accumulated profits (ss. 752-753)752. Purchases of shares by financial concerns and persons exempted from tax.753. Restriction on relief for losses by repayment of tax in case of dividends paid out of accumulated profits.Chapter 3 Stock borrowing and repurchase agreements (ss. 753A-753F)753A. Interpretation (Chapter 3).753B. Application.753C. Payment and receipt of dividends or interest and manufactured payments under a stock borrowing or repurchase agreement.753D. Refund of dividend withholding tax.753E. Anti-avoidance.753F. Records.Part 29 Patents, Scientific and Certain Other Research, Know-How and Certain Training (ss. 754-769R)Chapter 1 Patents (ss. 754-762)754. Interpretation (Chapter 1).755. Annual allowances for capital expenditure on purchase of patent rights.756. Effect of lapse of patent rights.757. Charges on capital sums received for sale of patent rights.758. Relief for expenses.759. Spreading of revenue payments over several years.760. Capital sums: effect of death, winding up and partnership changes.761. Manner of making allowances and charges.762. Application of Chapter 4 of Part 9.Chapter 2 Scientific and certain other research (ss. 763-767)763. Interpretation (sections 764 and 765).764. Deduction for revenue expenditure on scientific research.765. Allowances for capital expenditure on scientific research.766. Tax credit for research and development expenditure.766A. Tax credit on expenditure on buildings or structures used for research and development.766B. Limitation of tax credits to be paid under section 766 or 766A.766C. Research and development corporation tax credit.766D. Research and development corporation tax credit: expenditure on buildings or structures.767. Payment to universities and other approved bodies for research in, or teaching of, approved subjects.Chapter 3 Know-how and certain training (ss. 768-769)768. Allowance for know-how.769. Relief for training of local staff before commencement of trading.Chapter 4 Transmission Capacity Rights (ss. 769A-769F)769A. Interpretation (Chapter 4).769B. Annual allowances for capital expenditure on purchase of capacity rights.769C. Effect of lapse of capacity rights.769D. Manner of making allowances and charges.769E. Application of Chapter 4 of Part 9.769F. Commencement (Chapter 4).Chapter 5 Taxation of companies engaged in knowledge development (ss. 769G-769R)769G. Interpretation and general.769H. Families of products and assets.769I. Corporation tax referable to a specified trade.769J. Interaction with sections 766, 766A and 766B.769K. Adaptation of provisions relating to relief for relevant trading losses and relevant charges on income.769L. Documentation.769M. Anti-avoidance.769N. Application of Part 35A.769O. Transitional measures.769P. Time limits.769Q. Application.769R. Companies with income arising from intellectual property of less than €7,500,000.Part 30 Occupational Pension Schemes, Retirement Annuities, Purchased Life Annuities and Certain Pensions (ss. 770-790E)Chapter 1 Occupational pension schemes (ss. 770-782A)770. Interpretation and supplemental (Chapter 1).771. Meaning of "retirement benefits scheme".772. Conditions for approval of schemes and discretionary approval.772A. Approval of retirement benefits products.773. General Medical Services: scheme of superannuation.774. Certain approved schemes: exemptions and reliefs.775. Certain approved schemes: provisions supplementary to section 774(6).776. Certain statutory schemes: exemptions and reliefs.777. Charge to income tax in respect of certain relevant benefits provided for employees.778. Exceptions to charge to tax under section 777.779. Charge to income tax of pensions under Schedule E.779A. Transactions deemed to be pensions in payment.780. Charge to income tax on repayment of employees' contributions.781. Charge to income tax: commutation of entire pension.782. Charge to tax: repayments to employer.782A. Pre-retirement access to AVCs.Chapter 2 Retirement annuities (ss. 783-787)784BA. Annual returns by qualifying fund managers 783. Interpretation and general (Chapter 2).784. Retirement annuities: relief for premiums.784A. Approved retirement fund.784B. Conditions relating to an approved retirement fund.784C. Approved minimum retirement fund.784D. Conditions relating to an approved minimum retirement fund.784E. Returns, and payment of tax, by qualifying fund managers.785. Approval of contracts for dependants or for life assurance.786. Approval of certain other contracts.787. Nature and amount of relief for qualifying premiums.Chapter 2A Personal Retirement Savings Accounts (ss. 787A-787L)787A. Interpretation and supplemental.787B. Relevant earnings and net relevant earnings.787C. PRSAs - method of granting relief for PRSA contributions.787D. Claims to relief.787E. Extent of relief.787F. Transfers to PRSAs.787G. Taxation of payments from a PRSA.787H. Approved Retirement Fund option.787I. Exemption of PRSA.787J. Allowance to employer.787K. Revenue approval of PRSA products.787L. Transfers to and from PRSA.Chapter 2B Overseas Pension Plans: Migrant Member Relief (ss. 787M-787N)787M. Interpretation and general (Chapter 2B).787N. Qualifying overseas pension plans: relief for contributions.Chapter 2C Limit on Tax-Relieved Pension Funds (ss. 787O-787U)787O. Interpretation and general (Chapter 2C).787P. Maximum tax-relieved pension fund.787Q. Chargeable excess.787R. Liability to tax and rate of tax on chargeable excess.787RA. Credit for tax paid on an excess lump sum.787S. Payment of tax due on chargeable excess.787T. Discharge of administrator from tax.787TA. Encashment option.787TB. Penalties.787U. Regulations (Chapter 2C).Chapter 2D Pan-European Pension Product (ss. 787V-787AD)787V. Interpretation.787W. Relevant earnings and net relevant earnings.787X. PEPPs - Method of granting relief for PEPP contributions.787Y. Claims to relief.787Z. PEPP - Extent of relief.787AA. Taxation of payments from a PEPP.787AB. Approved Retirement Fund option.787AC. Exemption of PEPP.787AD. Allowance to employer.Chapter 2E Automatic Enrolment Retirement Savings System (ss. 787AE-787AI)787AE. Interpretation (Chapter 2E)787AF. Allowance to employer 787AG. Repayments to employer 787AH. Exemption of AE provider schemes 787AI. Taxation of payments from automatic enrolment retirement savings system Chapter 3 Purchased life annuities (ss. 788-789)788. Capital element in certain purchased annuities.789. Supplementary provisions (Chapter 3).Chapter 4 Miscellaneous (s. 790-790F)790. Liability of certain pensions, etc. to tax.790A. Limit on earnings.790AA. Taxation of lump sums in excess of the tax free amount.790B. Exemption of cross-border scheme.790C. Relief for deduction under Financial Emergency Measures in the Public Interest Act 2009.790CA. Relief for additional superannuation contribution under Public Service Pay and Pensions Act 2017 790D. Imputed distribution from certain funds.790E. Taxation of certain investment returns to relevant pension arrangements.790F. Exemption from income tax of rental income subject to registration with Residential Tenancies Board.Part 31 Taxation of Settlors, Etc., in Respect of Settled or Transferred Income (ss. 791-798)Chapter 1 Revocable dispositions for short periods and certain dispositions in favour of children (ss. 791-793)791. Income under revocable dispositions.792. Income under dispositions for short periods.793. Recovery of tax from trustee and payment to trustee of excess tax recoupment.Chapter 2 Settlements on children generally (ss. 794-798)794. Interpretation and application (Chapter 2).795. Income settled on children.796. Irrevocable instruments.797. Recovery of tax from trustee and payment to trustee of excess tax recoupment.798. Transfer of interest in trade to children.Part 32 Estates of Deceased Persons in Course of Administration and Surcharge on Certain Income of Trustees (ss. 799-805)Chapter 1 Estates of deceased persons in course of administration (ss. 799-804)799. Interpretation (Chapter 1).800. Limited interest in residue.801. Absolute interest in residue.802. Supplementary provisions as to absolute interest in residue.803. Special provisions as to certain interests.804. Adjustments and information.Chapter 2 Surcharge on certain income of trustees (s. 805)805. Surcharge on certain income of trustees.Part 33 Anti-Avoidance (ss. 806-817I)Chapter 1 Transfer of assets abroad (ss. 806-810)806. Charge to income tax on transfer of assets abroad.807. Deductions and reliefs in relation to income chargeable to income tax under section 806.807A. Liability of non-transferors.807B. Certain transitional arrangements in relation to transfer of assets abroad.807C. Supplementary provisions in relation to section 806 - apportionment in certain cases.808. Power to obtain information.809. Saver.810. Application of Income Tax Acts.Chapter 2 Miscellaneous (ss. 811-817C)811. Transactions to avoid liability to tax.811A. Transactions to avoid liability to tax: surcharge, interest and protective notification.811B. Tax treatment of loans from employee benefit schemes.811C. Transactions to avoid liability to tax.811D. Transactions to avoid liability to tax: surcharge, interest and protective notifications.812. Taxation of income deemed to arise from transfers of right to receive interest from securities.813. Taxation of transactions associated with loans or credit.814. Taxation of income deemed to arise from transactions in certificates of deposit and assignable deposits.815. Taxation of income deemed to arise on certain sales of securities.816. Taxation of shares issued in place of cash dividends.817. Schemes to avoid liability to tax under Schedule F.817A. Restriction of relief for payments of interest.817B. Treatment of interest in certain circumstances.817C. Restriction on deductibility of certain interest.Chapter 3 Mandatory Disclosure of Certain Transactions (ss. 817D-817R)817D. Interpretation and general (Chapter 3).817DA. References to 'specified description' - classes of transaction for purposes of that expression.817E. Duties of promoter.817F. Duty of person where promoter is outside the State.817G. Duty of person where there is no promoter.817H. Duty of person where legal professional privilege claimed.817HA. Duty of person who obtains tax advantage.817HB. Duty of Revenue Commissioners.817I. Pre-disclosure enquiry.817J. Legal professional privilege.817K. Supplemental information.817L. Duty of marketer to disclose.817M. Duty of promoter to provide client list.817N. Supplemental matters.817O. Penalties.817P. Appeal Commissioners.817Q. Regulations (Chapter 3).817R. Nomination of Revenue Officers.Chapter 3A Implementation of Council Directive (EU) 2018/822 of 25 May 2018 [OJ No. L139, 5.6.2018, p.1] amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (ss. 817RA-817RI)817RA. Interpretation (Chapter 3A).817RB. Application of Chapter 3A.817RC. Duties of intermediary.817RD. Duties of relevant taxpayer.817RE. Duties of Revenue Commissioners.817REA. Revenue powers.817RF.Arrangements implemented before 1 July 2020.817RG. Exchange of information.817RH. Penalties.817RI. Specified arrangements Chapter 4 Payment notices and scheme participants (ss. 817S-817T)817S. Payment notices.817T. Payment notices and scheme participants.Chapter 5 Outbound payments defensive measures (ss. 817U-817Z)817U. Interpretation.817V. Payment of interest.817W. Payment of royalties.817X. Making of distribution.817Y. Reporting.817Z. Scope of application.Part 34 Provisions Relating to the Residence of Individuals (ss. 818-825C)818. Interpretation (Part 34).819. Residence.820. Ordinary residence.821. Application of sections 17 and 18(1) and Chapter 1 of Part 3.822. Split year residence.823. Deduction for income earned outside the State.823A. Deduction for income earned in certain foreign states.824. Appeals.825. Residence treatment of donors of gifts to the State.825A. Reduction in income tax for certain income earned outside the State.825B. Repayment of tax where earnings not remitted.825C. Special assignee relief programme.Part 35 Double Taxation Relief (ss. 826-835)Chapter 1 Principal reliefs (ss. 826-829)826. Agreements for relief from double taxation.826A. Unilateral relief from double taxation.826B. Repayment of tax in case of ceased company: double taxation relief.827. Application to corporation tax of arrangements made in relation to corporation profits tax under old law.828. Capital gains tax: double taxation relief.829. Treatment for double taxation relief purposes of foreign tax incentive reliefs.Chapter 2 Miscellaneous (ss. 830-835)830. Relief to certain companies liable to foreign tax.831. Implementation of Council Directive No. 90/435/EEC concerning the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States.831A. Treatment of distributions to certain parent companies.831B. Participation exemption for certain foreign distributions 832. Provisions in relation to Convention for reciprocal avoidance of double taxation in the State and the United Kingdom of income and capital gains.833. Convention with United States of America.834. Relief in respect of ships documented under laws of United States of America.835. Saver for arrangements made under section 362 of Income Tax Act, 1967.Part 35A Transfer Pricing (ss. 835A-835HB)835A. Interpretation.835B. Meaning of associated.835C. Basic rules on transfer pricing.835D. Principles for construing rules in accordance with OECD Guidelines.835DA. OECD Pillar One - Amount B.835E. Modification of basic rules on transfer pricing for arrangements between qualifying persons 835EA. Small or medium-sized enterprise.835F. Small or medium-sized enterprise.835G. Documentation and enquiries.835H. Elimination of double counting.835HA. Interaction with capital allowances provisions.835HB. Interaction with provisions dealing with chargeable gains.Part 35B Implementation of Articles 7 and 8 of Council Directive (EU) 2016/1164 of 12 July 2016 (Controlled Foreign Companies) (ss. 835I-835Y)Chapter 1 Interpretation (ss. 835I-835P)835I. Interpretation 835J. Meaning of 'control'835K. Accounting periods 835L. Application of Part to a controlled foreign company 835M. Determination of residence 835N. Adjustment to amount of foreign tax 835O. Corresponding chargeable profits in the State 835P. Corresponding corporation tax in the State Chapter 2 Controlled foreign company charge (ss. 835Q-835S)835Q. Undistributed income 835R. Controlled foreign company charge 835S. Creditable tax Chapter 3 Exemptions (ss. 835T-835YA)835T. Effective tax rate exemption 835U. Low profit margin exemption 835V. Low accounting profit exemption 835W. Exempt period exemption 835X. Relief for certain distributions 835Y. Relief on certain disposals of shares or securities in a controlled foreign company 835YA. Non-cooperative jurisdictions: modified application of sections 835T, 835U and 835V.Part 35C Implementation of Council Directive (EU) 2016/1164 of 12 July 2016 as regards hybrid mismatches (ss. 835Z-835AX)Chapter 1 Interpretation and general (Part 35C) (ss. 835Z-835AB)835Z. Interpretation (Part 35C)835AA. Associated enterprises 835AB. Worldwide system of taxation Chapter 2 Double deduction (ss. 835AC-835AD)835AC. Application of Chapter 2 835AD. Double deduction mismatch outcome Chapter 3 Permanent establishments (ss. 835AE-835AG)835AE. Application of Chapter 3 835AF. Disregarded permanent establishment 835AG. Permanent establishment deduction without inclusion mismatch outcome Chapter 4 Financial instruments (ss. 835AH-835AJ)835AH. Interpretation (Chapter 4)835AI. Application of Chapter 4 835AJ. Financial instrument deduction without inclusion mismatch outcome Chapter 5 Hybrid entities (ss. 835AK-835AM)835AK. Application of Chapter 5 835AL. Payment to hybrid entity deduction without inclusion mismatch outcome 835AM. Payment by hybrid entity deduction without inclusion mismatch outcome Chapter 6 Withholding tax (ss. 835AN-835AO)835AN. Application of Chapter 6 835AO. Withholding tax mismatch outcome Chapter 7 Tax residency mismatch (ss. 835AP-835AQ)835AP. Application of Chapter 7 835AQ. Tax residency double deduction mismatch outcome Chapter 8 Imported mismatch outcomes (ss. 835AR-835AS)835AR. Application of Chapter 8 835AS. Imported mismatch outcome Chapter 9 Structured arrangements (ss. 835AT-835AU)835AT. Application of Chapter 9 835AU. Structured arrangements Chapter 10 Carry forward (s. 835AV)835AV. Carry forward Chapter 10A Reverse hybrid mismatches (ss. 835AVA-835AVD)835AVA. Interpretation (Chapter 10A)835AVB. Collective investment scheme 835AVC. Application (Chapter 10A)835AVD. Reverse hybrid mismatch outcome Chapter 11 Application of this Part (ss. 835AW-835AX)835AW. Scope of application 835AX. Order of application Part 35D Implementation of Council Directive (EU) 2016/1164 of 12 July 2016 as regards interest limitation (ss. 835AY-835AAO)Chapter 1 Interpretation and general (Part 35D) (ss. 835AY-835AAA)835AY. Interpretation (Part 35D)835AZ. Relevant profit and loss.835AAA. Long-term public infrastructure projects Chapter 2 Interest limitation (ss. 835AAB-835AAF)835AAB. Interpretation (Chapter 2).835AAC. Interest limitation 835AAD. Carry forward of disallowable amount.835AAE. Carry forward of total spare capacity.835AAF. Reporting Chapter 3 Group and equity ratio (ss. 835AAG-835AAJ)835AAG. Interpretation (Chapter 3).835AAH. Group ratio 835AAI. Equity ratio.835AAJ. Election Chapter 4 Application of this Part to interest groups (835AAK-835AAM)835AAK. Interpretation (Chapter 4)835AAL. Application of Part to interest group 835AAM. Interest group reporting Chapter 5 Application of this Part (835AAN-835AAO)835AAN. Scope of application 835AAO. Order of application Part 36 Miscellaneous Special Provisions (ss. 836-848A)836. Allowances for expenses of members of Oireachtas.837. Members of the clergy and ministers of religion.838. Special portfolio investment accounts.839. Limits to special investments.840. Business entertainment.840A. Interest on loans to defray money applied for certain purposes.841. Voluntary Health Insurance Board: restriction of certain losses and deemed disposal of certain assets.842. Replacement of harbour authorities by port companies.843. Capital allowances for buildings used for third level educational purposes.843A. Capital allowances for buildings used for certain childcare purposes.843B. Capital allowances for buildings used for the purposes of providing childcare services or a fitness centre to employees 844. Companies carrying on mutual business or not carrying on a business.845. Corporation tax: treatment of tax-free income of non-resident banks, insurance businesses, etc.845A. Non-application of section 130 in the case of certain interest paid by banks.845B. Set-off of surplus advance corporation tax.845C. Treatment of Additional Tier 1 instruments.846. Tax-free securities: exclusion of interest on borrowed money.847. Tax relief for certain branch profits.847A. Donations to certain sports bodies.847AA. Deduction for donations to National Governing Bodies.847B. Tax treatment of return of value on certain shares.847C. Tax treatment of return of value on certain shares where shareholders affected by postal delays.848. Designated charities: repayment of tax in respect of donations.848A. Donations to approved bodies.Part 36A Special savings incentive accounts (ss. 848B-848U)848B. Interpretation.848C. Special savings incentive account.848D. Tax credits.848E. Payment of tax credit.848F. Declaration on commencement.848G. Acquisition of qualifying assets.848H. Termination of special savings incentive account.848I. Declaration on maturity.848J. Gain on maturity.848K. Gain on cessation.848L. Gain on withdrawal.848M. Taxation of gains.848N. Transfer of special savings incentive account.848O. Declaration on transfer.848P. Monthly returns.848Q. Annual returns.848QA. Other returns.848R. Registration etc.848S. Regulations.848T. Offences.848U. Disclosure of information.Part 36B Pensions: incentive tax credits (ss. 848V-848AG)848V. Interpretation (Part 36B).848W. Transfer of funds on maturity of SSIA.848X. Declaration.848Y. Entitlement to pension tax credit.848Z. Tax credits.848AA. Payment of tax credits.848AB. Monthly return.848ABA. Withdrawal of tax credits.848AC. Other returns.848AD. Registration and audit of administrators.848AE. Regulations (Part 36B).848AF. Offences (Part 36B).848AG. Retention of declarations.Management Provisions (ss. 849-1104)Part 37 Administration (ss. 849-875)849. Taxes under care and management of Revenue Commissioners.850. Appeal Commissioners.851. Collector-General.851A. Confidentiality of taxpayer information.851B. Use of, and access to, taxpayer information 852. Inspectors of taxes.853. Governor and directors of Bank of Ireland.854. Appointment of persons for purposes of assessment of certain public offices.855. Declaration to be made by Commissioners.856. Disqualification of Commissioners in cases of personal interest.857. Declarations on taking office.858. Evidence of authorisation.859. Anonymity of authorised officers in relation to certain matters.860. Administration of oaths.861. Documents to be in accordance with form prescribed by Revenue Commissioners.862. Exercise of powers, etc. of Minister for Finance under Tax Acts.863. Loss, destruction or damage of assessments and other documents.864. Making of claims, etc.864A. Electronic claims.865. Repayment of tax.865A. Interest on repayments.865B. No offset where repayment prohibited.866. Rules as to delivery of statements.867. Amendment of statutory forms.868. Execution of warrants.869. Delivery, service and evidence of notices and forms.870. Effect of want of form, error, etc. on assessments, charges, warrants and other proceedings.871. Power to combine certain returns and assessments.872. Use of information relating to other taxes and duties.873. Proof that person is a Commissioner or officer.874. Limitation of penalties on officers employed in execution of Tax Acts and Capital Gains Tax Acts.874A. Prescribing of forms, etc.875. Exemption of appraisements and valuations from stamp duty.Part 38 Returns of income and gains, other obligations and returns, and revenue powers (ss. 876-917N)Chapter 1 Income tax: returns of income (ss. 876-881)876. Notice of liability to income tax.877. Returns by persons chargeable.878. Persons acting for incapacitated persons and non-residents.879. Returns of income.880. Partnership returns.881. Returns by married persons.Chapter 2 Corporation tax: returns of profits (ss. 882-884)882. Particulars to be supplied by new companies.883. Notice of liability to corporation tax.884. Returns of profits.Chapter 3 Other obligations and returns (ss. 885-898A)885. Obligation to show tax reference number on receipts.886. Obligation to keep certain records.886A. Retention and inspection of records in relation to claims by individuals.887. Use of electronic data processing.888. Returns, etc. by lessors, lessees and agents.889. Returns of fees, commissions, etc. paid by certain persons.890. Returns by persons in receipt of income belonging to others.891. Returns of interest paid or credited without deduction of tax.891A. Returns of interest paid to non-residents.891B. Returns of certain payments made by certain persons.891C. Returns of certain information by investment undertakings.891D. Returns of payment transactions by payment settlers.891DA. Returns of certain payment card transactions by payment card providers 891E. Implementation of the Agreement to Improve Tax Compliance and Provide for Reporting and Exchange of Information concerning Tax Matters (United States of America) Order 2013.891F. Returns of certain information by financial institutions.891G. Implementation of Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation.891GA. Disclosure of certain information for the purposes of administrative cooperation in the field of taxation 891H. Country-by-country reporting.891HA.891I. Implementation of Article 1(8) of Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to platform operators 891J. Return of certain information by Reporting Platform Operators 891K. Implementation of Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation in relation to presence requests 891L. Implementation of Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation in relation to joint audits.891M. Implementation of paragraphs (6) and (19) of Article 1 of Council Directive (EU) 2023/2226/EU of 17 October 2023 as regards mandatory automatic exchange of information in the field of taxation in relation to Reporting Crypto-Asset Service Providers 892. Returns by nominee holders of securities.893. Returns by certain intermediaries in relation to UCITS.894. Returns of certain information by third parties.894A. Returns by third parties in relation to personal reliefs.895. Returns in relation to foreign accounts.896. Returns in relation to certain offshore products.896A. Returns in relation to settlements and trustees.896B. Provision of information by Commission for Taxi Regulation.896C.897. Returns of employees' emoluments, etc.897A. Returns by employers in relation to pension products.897B. Returns of information in respect of awards of shares to directors and employees.897C. Returns by employers in relation to reportable benefits.898. Returns of copies of rates and production of certain valuations.898A. Format of returns etc.Chapter 3A Implementation of Council Directive 2003/48/EC of 3 June 2003 on taxation of savings income in the form of interest payments and related matters (ss. 898B-898S)898B. Interpretation (Chapter 3A).898C. Beneficial owner.898D. Paying agent and residual entity.898E. Interest payment.898F. Obligations of paying agents where contractual relations entered into before 1 January 2004.898G. Obligations of paying agents in other contractual relations entered into.898H. Returns of interest payments made to or secured for beneficial owners.898I. Returns of interest payments to residual entities.898J. Exchange of information between Member States.898K. Special arrangements for certain securities.898L. Certificate for the purposes of Article 13.2 of the Directive.898M. Credit for withholding tax.898N. Audit.898O. Penalty for failure to make returns, etc.898P. Arrangements with third countries and dependent and associated territories of Member States.898Q. Miscellaneous and supplemental.898R. Commencement (Chapter 3A).898S. Cessation Chapter 4 Revenue powers (ss. 899-912B)899. Inspector's right to make enquiries.900. Power to call for production of books, information, etc.901. Application to High Court: production of books, information, etc.902. Information to be furnished by third party: request of an authorised officer 902A. Application to High Court: information from third party.902B. Powers of inspection: life policies.903. Power of inspection: PAYE.904. Power of inspection: tax deduction from payments to certain subcontractors.904A. Power of inspection: returns and collection of appropriate tax.904B. Report to Committee of Public Accounts: publication etc.904C. Power of inspection (returns and collection of appropriate tax): assurance companies.904D. Power of inspection (returns and collection of appropriate tax): investment undertakings.904E. Power of inspection: claims by authorised insurers.904F. Power of inspection: claims by qualifying lenders.904G. Power of inspection: claims by qualifying insurers.904H. Power of inspection: qualifying savings managers.904I. Power of inspection: returns and collection of dividend withholding tax.904J. Power of inspection: tax deduction from payments in respect of professional services by certain persons.904K. Power of inspection: notices of attachment.905. Inspection of documents and records.906. Authorised officers and Garda Síochána.906A. Information to be furnished by financial institutions.907. Application to Appeal Commissioners: information from financial institutions.907A. Application to Appeal Commissioners: information from third party.908. Application to High Court seeking order requiring information: financial institutions.908A. Revenue offence: power to obtain information from financial institutions.908B. Application to High Court seeking order requiring information: associated institutions.908C. Search warrants.908D. Order to produce evidential material.908E. Order to produce documents or provide information.908F. Privileged legal material.909. Power to require return of property.910. Power to obtain information from Minister of the Government.911. Valuation of assets.912. Computer documents and records.912A. Information for tax authorities in other territories.912B. Questioning of suspects in Garda Síochána custody in certain circumstances.Chapter 5 Capital gains tax: returns, information, etc. (ss. 913-917C)913. Application of income tax provisions relating to returns, etc.914. Returns by issuing houses, stockbrokers, auctioneers, etc.915. Returns by nominee shareholders.916. Returns by party to a settlement.917. Returns relating to non-resident companies and trusts.917A. Return of property transfers to non-resident trustees.917B. Return by settlor in relation to non-resident trustees.917C. Return by certain trustees.Chapter 6 Electronic transmission of returns of income, profits, etc., and of other Revenue returns (ss. 917D-917N)917D. Interpretation (Chapter 6).917E. Application.917EA. Mandatory electronic filing and payment of tax.917F. Electronic transmission of returns.917G. Approved persons.917H. Approved transmissions.917I. Digital signatures.917J. Acknowledgement of electronic transmissions.917K. Hard copies.917L. Exercise of powers.917M. Proceedings.917N. Miscellaneous.Part 39 Assessments (ss. 918-931)Chapter 1 Income tax and corporation tax (ss. 918-928)918. Making of assessments under Schedules C, D, E and F.919. Assessments to corporation tax.920. Granting of allowances and reliefs.921. Aggregation of assessments.922. Assessment in absence of return.923. Function of certain assessors.924. Additional assessments.925. Special rules relating to assessments under Schedule E.926. Estimation of certain amounts.927. Rectification of excessive set-off, etc. of tax credit.928. Transmission to Collector-General of particulars of sums to be collected.Chapter 2 Provision against double assessment and relief for error or mistake (ss. 929-930)929. Double assessment.930. Error or mistake.Chapter 3 Capital gains tax (s. 931)931. Making of assessments and application of income tax assessment provisions.Part 40 Appeals (ss. 932-949)Chapter 1 Appeals against income tax and corporation tax assessments (ss. 932-944A)932. Prohibition on alteration of assessment except on appeal.933. Appeals against assessment.934. Procedure on appeals.935. Power to issue precepts.936. Objection by inspector or other officer to schedules.937. Confirmation and amendment of assessments.938. Questions as to assessments or schedules.939. Summoning and examination of witnesses.940. Determination of liability in cases of default.941. Statement of case for High Court.942. Appeals to Circuit Court.943. Extension of section 941.944. Communication of decision of Appeal Commissioners.944A. Publication of determinations of Appeal Commissioners.Chapter 2 Appeals against capital gains tax assessments (ss. 945-946)945. Appeals against assessments.946. Regulations with respect to appeals.Chapter 3 Miscellaneous (ss. 947-949)947. Appeals against determination under sections 98 to 100.948. Appeals against amount of income tax deducted under Schedule E.949. Appeals against determinations of certain claims, etc.Part 40A Appeals to Appeals Commissioners (ss. 949A-949AX)Chapter 1 Interpretation and General (ss. 949A-949H)949A. Interpretation 949B. Delegation of acts and functions of the Revenue Commissioners 949C. Electronic means 949D. Persons acting under authority 949E. Directions 949F. Joining of additional parties to appeal 949G. Withdrawal and dismissal of appeals 949H. Flexible proceedings Chapter 2 Making and acceptance of appeals (ss. 949I-949P)949I. Notice of appeal 949J. Valid appeal and references in this Part to acceptance of an appeal 949K. Notification of appeal to Revenue Commissioners 949L. Objection by Revenue Commissioners 949M. Acceptance of an appeal 949N. Refusal to accept an appeal 949O. Late appeals 949P. Effect of enforcement action for collection of tax Chapter 3 Pre-hearing proceedings (ss. 949Q-949W)949Q. Statement of case 949R. Exchange of statement of case 949S. Outline of arguments 949T. Case management conference 949U. Adjudication without a hearing 949V. Settlement of appeal by agreement 949W. Staying proceedings Chapter 4 Hearings (ss. 949X-949AF)949X. Time and place for hearing 949Y. Public hearings 949Z. Exclusion from hearings 949AA. Parties' attendance at hearings 949AB. Parties' representatives 949AC. Evidence 949AD. Oath 949AE. Summoning and examination of witnesses 949AF. Oral determinations Chapter 5 Determinations (ss. 949AG-949AO)949AG. Appeal Commissioners to have regard to same matters as Revenue Commissioners 949AH. Mode of proceeding if appeal adjudicated on by way of a hearing 949AI. Incomplete information 949AJ. Determinations and their notification 949AK. Determinations in relation to assessments 949AL. Determinations other than in relation to assessments 949AM. Revenue Commissioners to give effect to determinations 949AN. Appeals raising common or related issues 949AO. Publication of determinations Chapter 6 Appealing determinations of the Appeal Commissioners (ss. 949AP-AT)949AP. Appealing against determinations 949AQ. Case stated for High Court 949AR. Determinations of High Court 949AS. Appeal to Court of Appeal 949AT. Revenue Commissioners to give effect to decisions of High Court, Court of Appeal and Supreme Court Chapter 7 Penalties and Sanctions (ss. 949AU-949AV)949AU. Summoning and examination of witnesses 949AV. Dismissal of an appeal Chapter 8 Appeal Commissioner vacating office before completion of appeal (ss. 949AW-949AX)949AW. Appeal Commissioner vacating office: prior to determination 949AX. Appeal Commissioner vacating office: prior to completion and signing of case stated Part 41 Self Assessment (ss. 950-959)950. Interpretation (Part 41).951. Obligation to make a return.952. Obligation to pay preliminary tax.953. Notices of preliminary tax.954. Making of assessments.955. Amendment of and time limit for assessments.956. Inspector's right to make enquiries and amend assessments.957. Appeals.958. Date for payment of tax.959. Miscellaneous (Part 41).Part 41A Assessing Rules Including Rules for Self Assessment (ss. 959A-959AX)Chapter 1 Interpretation (Part 41A) (ss. 959A-959B)959A. Interpretation.959B. Supplemental interpretation provisions.Chapter 2 Assessments: General Rules (ss. 959C-959H)959C. Making of assessments: general rules.959D. Record of assessments and generation of notices by electronic means.959E. Notice of assessment by Revenue officer.959F. Double assessment.959G. Transmission to Collector-General of particulars of sums to be collected.959H. Amended assessment and notice of amended assessment.Chapter 3 Chargeable Persons: Returns (ss. 959I-959Q)959I. Obligation to make a return.959J. Requirements for returns for income tax and capital gains tax purposes.959K. Requirements for returns for corporation tax purposes.959L. Delivery of return by person acting under authority.959M. Delivery of return by precedent partner.959N. Exclusion from obligation to deliver a return.959O. Failure to deliver a return.959P. Expression of doubt.959Q. Miscellaneous (Chapter 3).Chapter 4 Chargeable Persons: Self Assessments (ss. 959R-959X)959R. Inclusion of self assessment in return.959S. Option for self assessment to be made by Revenue.959T. Self assessment by person acting under authority.959U. Self assessment by Revenue officer in relation to chargeable person.959V. Amendment by chargeable person of return and of self assessment in return.959W. Making of self assessment in accordance with return.959X. Penalty for failure to make or amend self assessment.Chapter 5 Revenue Assessments and Enquiries and Related Time Limits (ss. 959Y-959AE)959Y. Chargeable persons and other persons: assessment made or amended by Revenue officer.959Z. Right of Revenue officer to make enquiries.959AA. Chargeable persons: time limit on assessment made or amended by Revenue officer.959AB. Persons other than chargeable persons: time limit on Revenue assessment and amended assessment.959AC. Chargeable persons: Revenue assessment and amendment of assessments in absence of return, etc.959AD. Chargeable persons and other persons: Revenue assessment and amendment of assessments where there is fraud or neglect.959AE. Other Revenue assessments and miscellaneous matters.Chapter 6 Appeals (ss. 959AF-959AL)959AF. Appeals in relation to assessments.959AG. Chargeable persons: no appeal against self assessment.959AH. Chargeable persons: requirement to submit return and pay tax.959AI. Chargeable persons and other persons: no appeal against agreed amounts.959AJ. Appeals against time limits for making enquiries and taking actions.959AK. Appeals against amended assessments and provisions concerning preliminary matters.959AL. Persons other than chargeable persons: other rules.Chapter 7 Chargeable Persons: Preliminary Tax and Dates for Payment of Tax (ss. 959AM-959AV)959AM. Interpretation and miscellaneous (Chapter 7).959AN. Obligation to pay preliminary tax.959AO. Date for payment of income tax.959AP. Payment of preliminary tax by direct debit.959AQ. Date for payment of capital gains tax.959AR. Date for payment of corporation tax: companies other than with relevant accounting periods.959AS. Date for payment of corporation tax: companies with relevant accounting periods.959AT. Date for payment of corporation tax: groups.959AU. Date for payment of tax: amended assessments.959AV. Date for payment of tax: determination of an appeal.Chapter 8 Miscellaneous provisions (ss. 959AW-959AX)959AW. Mutual agreement procedures.959AX. Estimate of tax due.Part 42 Collection and Recovery (ss. 960-1006B)Chapter 1 Income tax (ss. 960-972)960. Date for payment of income tax other than under self assessment.961. Issue of demand notes and receipts.962. Recovery by sheriff or county registrar.963. Power of Collector-General and authorised officer to sue in Circuit Court or District Court.964. Continuance of pending proceedings.965. Evidence in proceedings in Circuit Court or District Court for recovery of income tax.966. High Court proceedings.967. Evidence of electronic transmission of particulars of income tax to be collected in proceedings for recovery of tax.968. Judgments for recovery of income tax.969. Duration of imprisonment for non-payment of income tax.970. Recovery of income tax charged on profits not distrainable.971. Priority of income tax debts over other debts.972. Duty of employer as to income tax payable by employees.Chapter 1A Interpretation (ss. 960A-960B)960A. Interpretation.960B. Discharge of Revenue Commissioners' and Collector-General's functions Chapter 1B Collection of tax, etc. (ss. 960C-960H)960C. Tax to be due and payable to Revenue Commissioners.960D. Tax to be debt due to Minister for Finance.960E. Collection of tax, issue of demands, etc.960EA. Payment of tax by relevant payment methods.960F. Moneys received for capital acquisitions tax and stamp duties and not appropriated to be recoverable.960G. Duty of taxpayer to identify liability against which payment to be set, etc.960GA. Repayment or refund of payment made in excess of liability to tax assessed by taxpayer 960H. Offset between taxes.Chapter 1C Recovery provisions, evidential rules, etc. (ss. 960I-960Q)960I. Recovery of tax by way of civil proceedings.960J. Evidential and procedural rules.960K. Judgments for recovery of tax.960L. Recovery by sheriff or county registrar.960M. Taking by Collector-General of proceedings in bankruptcy.960N. Continuance of pending proceedings and evidence in proceedings.960O. Winding-up of companies: priority for taxes.960P. Bankruptcy: priority for taxes.960Q. Recovery of amounts received by a person following the lodgement of an incorrect account, etc.Chapter 1D Power to require statement of affairs, security, etc. (ss. 960R-960S)960R. Power of Collector-General to require certain persons to provide return of property.960S. Security for certain taxes.Chapter 2 Corporation tax (ss. 973-975)973. Collection of corporation tax.974. Priority for corporation tax.975. Application of sections 964(2), 980(8) and 981 for purposes of corporation tax.Chapter 3 Capital gains tax (ss. 976-982)976. Collection of capital gains tax.977. Recovery of capital gains tax from shareholder.978. Gifts: recovery of capital gains tax from donee.979. Time for payment of capital gains tax assessed under sections 977(3) or 978(2) and (3).980. Deduction from consideration on disposal of certain assets.981. Payment by instalments where consideration due after time of disposal.982. Preferential payment.Chapter 4 Collection and recovery of income tax on certain emoluments (PAYE system) (ss. 983-997A)983. Interpretation (Chapter 4).984. Application.984A. Electronic system.984B. Liability for payment of deduction.985. Method of collection.985A. Application of section 985 to certain perquisites, etc.985B. PAYE settlement agreements.985C. PAYE: payment by intermediary.985D. PAYE: employee of non-resident employer, etc.985E. PAYE: employment not wholly exercised in State.985F. PAYE: mobile workforce.985G. Return by employer.985H. Exceptional circumstances.986. Regulations.986A. Payment made without deduction of income tax.987. Penalties for breach of regulations.988. Registration of certain persons as employers and requirement to send certain notifications.988A. Register of employees.989. Estimation of tax due for income tax months.990. Assessment of tax due.990A. Generation of assessments by electronic, photographic or other process.991. Interest.991A. Payment of tax by direct debit.991B. Covid-19: special warehousing and interest provisions.992. Appeals against estimates under section 989 or 990.993. Recovery of tax.994. Priority in bankruptcy, etc. of certain amounts.995. Priority in winding up of certain amounts.996. Treatment for tax purposes of certain unpaid remuneration.997. Supplementary provisions (Chapter 4).997A. Credit in respect of tax deducted from emoluments of certain directors.Chapter 5 Miscellaneous provisions (ss. 998-1006B)998. Recovery of moneys due.999. Taking by Collector-General of proceedings in bankruptcy.1000. Priority in bankruptcy, winding up, etc. for sums recovered or deducted under sections 531, 989 or 990.1001. Liability to tax, etc. of holder of fixed charge on book debts of company.1002. Deduction from payments due to defaulters of amounts due in relation to tax.1003. Payment of tax by means of donation of heritage items.1003A. Payment of tax by means of donation of heritage property to an Irish heritage trust.1004. Unremittable income.1005. Unremittable gains.1006. Poundage and certain other fees due to sheriffs or county registrars.1006A. Offset between taxes.1006B. Appropriation of payments.Part 43 Partnerships and European Economic Interest Groupings (EEIG) (ss. 1007-1014)1007. Interpretation (Part 43).1008. Separate assessment of partners.1008A. Medical practitioners operating in partnership 1009. Partnerships involving companies.1009A. Taxation of certain foreign body corporates.1010. Capital allowances and balancing charges in partnership cases.1011. Provision as to charges under section 757.1012. Modification of provisions as to appeals.1013. Limited partnerships.1014. Tax treatment of profits, losses and capital gains arising from activities of a European Economic Interest Grouping (EEIG).Part 44 Married, Separated and Divorced Persons (ss. 1015-1031)Chapter 1 Income tax (ss. 1015-1027)1015. Interpretation (Chapter 1).1016. Assessment as single persons.1017. Assessment of husband in respect of income of both spouses.1018. Election for assessment under section 1017.1019. Assessment of wife in respect of income of both spouses.1020. Special provisions relating to year of marriage.1021. Repayment of tax in case of certain husbands and wives.1022. Special provisions relating to tax on wife's income.1023. Application for separate assessments.1024. Method of apportioning reliefs and charging tax in cases of separate assessments.1025. Maintenance in case of separated spouses.1026. Separated and divorced persons: adaptation of provisions relating to married persons.1027. Payments pursuant to certain orders under Judicial Separation and Family Law Reform Act, 1989, Family Law Act, 1995, and Family Law (Divorce) Act, 1996, to be made without deduction of income tax.Chapter 2 Capital gains tax (ss. 1028-1031)1028. Married persons.1029. Application of section 1022 for purposes of capital gains tax.1030. Separated spouses: transfers of assets.1031. Divorced persons: transfers of assets.Part 44A Tax Treatment of Civil Partnerships (ss. 1031A-1031O)Chapter 1 Income Tax (ss. 1031A-1031K)1031A. Interpretation (Chapter 1).1031B. Assessment as single persons.1031C. Assessment of nominated civil partner in respect of income of both civil partners.1031D. Election for assessment under section 1031C.1031E. Special provisions relating to year of registration of civil partnership.1031F. Repayment of tax in case of certain civil partners.1031G. Special provisions relating to tax on individual's civil partner's income.1031H. Application for separate assessments.1031I. Method of apportioning reliefs and charging tax in cases of separate assessments.1031J. Maintenance of civil partners living apart.1031K. Dissolution or annulment of civil partnerships: adaptation of provisions relating to civil partners.Chapter 2 Capital Gains Tax (ss. 1031L-1031O)1031L. Interpretation (Chapter 2).1031M. Civil partners.1031N. Application of section 1031G for purposes of capital gains tax.1031O. Transfers of assets where civil partnership dissolved.Part 44B Tax Treatment of Cohabitants (ss. 1031P-1031R)Chapter 1 Income Tax (ss. 1031P-1031Q)1031P. Interpretation (Chapter 1).1031Q. Maintenance where relationship between cohabitants ends.Chapter 2 Capital Gains Tax (s. 1031R)1031R. Transfers of assets where relationship between cohabitants ends.Part 45 Charging and Assessing of Non-Residents (ss. 1032-1043)Chapter 1 Income tax and corporation tax (ss. 1032-1041)1032. Restrictions on certain reliefs.1033. Entitlement to tax credit in respect of distributions.1034. Assessment.1035. Profits from agencies, etc.1035A. Relieving provision to section 1035.1036. Control over residents.1037. Charge on percentage of turnover.1038. Merchanting profit.1039. Restrictions on chargeability.1040. Application of sections 1034 to 1039 for purposes of corporation tax.1041. Rents payable to non-residents.Chapter 2 Capital gains tax (ss. 1042-1043)1042. Charging and assessment of persons not resident or ordinarily resident: modification of general rules.1043. Application of sections 1034 and 1035 for purposes of capital gains tax.Part 46 Persons Chargeable in a Representative Capacity (ss. 1044-1051)Chapter 1 Income tax and corporation tax (ss. 1044-1050)1044. Bodies of persons.1045. Trustees, guardians and committees.1046. Liability of trustees, etc.1047. Liability of parents, guardians, executors and administrators.1048. Assessment of executors and administrators.1049. Receivers appointed by court.1050. Protection for trustees, agents and receivers.Chapter 2 Capital gains tax (s. 1051)1051. Application of Chapter 1 for purposes of capital gains tax.Part 47 Penalties, Revenue Offences, Interest on Overdue Tax and Other Sanctions (ss. 1052-1086)Chapter 1 Income tax and corporation tax penalties (ss. 1052-1070)1052. Penalties for failure to make certain returns, etc.1053. Penalty for fraudulently or negligently making incorrect returns, etc.1054. Penalties in the case of a secretary of a body of persons.1055. Penalty for assisting in making incorrect returns, etc.1056. Penalty for false statement made to obtain allowance.1057. Fine for obstruction of officers in execution of duties.1058. Refusal to allow deduction of tax.1059. Power to add penalties to assessments.1060. Proceedings against executor or administrator.1061. Recovery of penalties.1062. Proceedings where penalty recoverable cannot be definitely ascertained.1063. Time limit for recovery of fines and penalties.1064. Time for certain summary proceedings.1065. Mitigation and application of fines and penalties.1066. False evidence: punishment as for perjury.1067. Admissibility of statements and documents in criminal and tax proceedings.1068. Failure to act within required time.1069. Evidence of income.1070. Saving for criminal proceedings.Chapter 2 Other corporation tax penalties (ss. 1071-1076)1071. Penalties for failure to make certain returns.1072. Penalties for fraudulently or negligently making incorrect returns, etc.1073. Penalties for failure to furnish particulars required to be supplied by new companies.1074. Penalties for failure to give notice of liability to corporation tax.1075. Penalties for failure to furnish certain information and for incorrect information.1076. Supplementary provisions (Chapter 2).Chapter 3 Capital gains tax penalties (s. 1077)1077. Penalties for failure to make returns, etc. and for deliberately or carelessly making incorrect returns.Chapter 3A Determination of Penalties and Recovery of Penalties (ss. 1077A-1077D)1077A. Interpretation (Chapter 3A).1077B. Penalty notifications and determinations.1077C. Recovery of penalties.1077D. Proceedings against executor, administrator or estate.Chapter 3B Income Tax, Corporation Tax and Capital Gains Tax: Penalties for false returns, etc. (ss. 1077E-1077F)1077E. Penalty for deliberately or carelessly making incorrect returns, etc.1077F. Penalty for deliberately or carelessly making incorrect returns or failing to make certain returns, etc.Chapter 4 Revenue offences (ss. 1078-1079)1078. Revenue offences.1078A. Concealing facts disclosed by documents.1078B. Presumptions.1078C. Provision of information to juries.1079. Duties of relevant person in relation to certain revenue offences.Chapter 5 Interest on overdue tax (ss. 1080-1083)1080. Interest on overdue income tax, corporation tax and capital gains tax.1080A. Interest on overdue tax - supplementary provision.1080B. Covid-19: special warehousing and interest provisions (income tax).1080C. Covid-19: interest charge on relevant person under section 1080B.1081. Effect on interest of reliefs given by discharge or repayment.1082. Interest on overdue income tax and corporation tax in cases of fraud or neglect.1083. Application of sections 1080 to 1082 for capital gains tax purposes.Chapter 6 Other sanctions (ss. 1084-1086A)1084. Surcharge for late returns.1085. Corporation tax - late returns: restriction of certain claims for relief.1086. Publication of names of tax defaulters.1086A. Publication of names and details of tax defaulters.Part 48 Miscellaneous and Supplemental (ss. 1087-1096B)1087. Charge and deduction of income tax not charged or deducted before passing of annual Act.1088. Restriction on deductions in computing profits.1089. Status of interest on certain unpaid taxes and duties.1090. Income tax assessment to be conclusive of total income.1091. Annexation of statements to interest warrants, etc.1092. Disclosure of certain information to rating authorities, etc.1093. Disclosure of information to Ombudsman.1093A. Disclosure of certain information to Minister for Enterprise, Trade and Employment, etc.1094. Tax clearance certificates in relation to certain licences.1095. Tax clearance certificates: general scheme.1096. Assessment of Electricity Supply Board.1096A. Construction of references to oaths, etc.1096B. Evidence of computer stored records in court proceedings etc.Part 49 Commencement, Repeals, Transitional Provisions, Etc. (ss. 1097-1104)1097. Commencement.1098. Repeals.1099. Saving for enactments not repealed.1100. Consequential amendments to other enactments.1101. Transitional provisions.1102. Continuity and construction of certain references to old and new law.1103. Continuance of officers, instruments and documents.1104. Short title and construction.Schedules Schedule 1 Supplementary Provisions Concerning the Extension of Charge to Tax to Profits and Income Derived from Activities Carried On and Employments Exercised on the Continental Shelf Schedule 2 Machinery for Assessment, Charge and Payment of Tax under Schedule C and, in Certain Cases, Schedule D Schedule 2, Part 1 Interpretation of Parts 2 to 4 (paras. 1-1A)Schedule 2, Part 2 Public revenue dividends, etc., payable to the Bank of Ireland, or entrusted for payment to the Bank of Ireland (paras. 2-10)Schedule 2, Part 3 Public revenue dividends payable by public offices and departments (paras. 11-13)Schedule 2, Part 4 Public revenue dividends, dividends to which Chapter 2 of Part 4 applies, proceeds of coupons and price paid on purchase of coupons (paras. 14-22)Schedule 2, Part 5 Relief from obligation to pay tax on certain interest, dividends and other annual payments in the case of persons entrusted with payment (paras. 23-28)Schedule 2A Dividend withholding tax Schedule 2B Investment Undertakings: Declarations Schedule 2C Irish Real Estate Funds: Declarations Schedule 3 Reliefs in Respect of Income Tax Charged on Payments on Retirement, etc Schedule 3, Part 1 Interpretation and preliminary (paras. 1-5)Schedule 3, Part 2 Relief by reduction of sums chargeable (paras. 6-9A)Schedule 3, Part 3 Relief by reduction of tax (paras. 10-14)Schedule 4 Exemption of Specified Non-Commercial State Sponsored Bodies from Certain Tax Provisions Schedule 4A Acceleration of wear and tear allowances for certain energy-efficient equipment.Schedule 5 Description of Custom House Docks Area Schedule 6 Description of Temple Bar Area Schedule 7 Description of Certain Enterprise Areas Schedule 7, Part 1 Interpretation Schedule 7, Part 2 Description of Cherry Orchard/Gallanstown Enterprise Area Schedule 7, Part 3 Description of Finglas Enterprise Area Schedule 7, Part 4 Description of Rosslare Harbour Enterprise Area Schedule 8 Description of Qualifying Resort Areas Schedule 8, Part 1 Description of qualifying resort areas of Clare Schedule 8, Part 2 Description of qualifying resort areas of Cork Schedule 8, Part 3 Description of qualifying resort areas of Donegal Schedule 8, Part 4 Description of qualifying resort areas of Galway Schedule 8, Part 5 Description of qualifying resort areas of Kerry Schedule 8, Part 6 Description of qualifying resort areas of Louth Schedule 8, Part 7 Description of qualifying resort areas of Mayo Schedule 8, Part 8 Description of qualifying resort areas of Meath Schedule 8, Part 9 Description of qualifying resort areas of Sligo Schedule 8, Part 10 Description of qualifying resort areas of Waterford Schedule 8, Part 11 Description of qualifying resort areas of Wexford Schedule 8, Part 12 Description of qualifying resort areas of Wicklow Schedule 8A Description of Qualifying Rural Areas Schedule 8B Description of Qualifying Mid-Shannon Areas Schedule 9 Change in Ownership of Company: Disallowance of Trading Losses Schedule 10 Relief for Investment in Corporate Trades: Subsidiaries Schedule 11 Profit Sharing Schemes Schedule 11, Part 1 Interpretation (paras. 1-2)Schedule 11, Part 2 Approval of schemes (paras. 3-7)Schedule 11, Part 3 Conditions as to the shares (paras. 8-11A)Schedule 11, Part 4 Individuals ineligible to participate (paras. 12-14)Schedule 11, Part 5 Provisions as to the trust instrument (paras. 15-18)Schedule 12 Employee Share Ownership Trusts Schedule 12A Approved Savings-Related Share Option Schemes Schedule 12B Certified Contractual Savings Schemes Schedule 12C Approved Share Option Schemes Schedule 13 Accountable Persons for Purposes of Chapter 1 of Part 18 Schedule 14 Capital Gains Tax: Leases Schedule 15 List of Bodies for Purposes of Section 610 Schedule 15, Part 1 Schedule 15, Part 2 Schedule 16 Building Societies: Change of Status Schedule 17 Reorganisation into Companies of Trustee Savings Banks Schedule 17A Accounting Standards Schedule 18 Accounting for and Payment of Tax Deducted from Relevant Payments and Undistributed Relevant Income Schedule 18A Restriction on set-off of pre-entry losses Schedule 18B Tonnage Tax Schedule 18B, Part 1 Matters relating to election for tonnage tax (paras. 1-6)Schedule 18B, Part 2 Matters relating to qualifying ships (paras. 7-9)Schedule 18B, Part 3 Capital Allowances, Balancing Charges and Related Matters (paras. 10-20)Schedule 18B, Part 4 Groups, Mergers and Related Matters (paras. 21-30)Schedule 18B, Part 5 Miscellaneous and supplemental (paras. 31-34)Schedule 19 Offshore Funds: Distributing Funds Schedule 19, Part 1 The Distribution Test Schedule 19, Part 2 Modifications of Conditions for Certification in Certain Cases Schedule 19, Part 3 Certification Procedure Schedule 19, Part 4 Supplementary Schedule 20 Offshore Funds: Computation of Offshore Income Gains Schedule 20, Part 1 Disposal of Interests in non-qualifying funds Schedule 20, Part 2 Disposals involving an equalisation element Schedule 21 Purchase and Sale of Securities: Appropriate Amount in Respect of the Interest Schedule 22 Dividends Regarded as Paid Out of Profits Accumulated Before Given Date Schedule 23 Occupational Pension Schemes Schedule 23, Part 1 General Schedule 23, Part 2 Charge to tax in respect of unauthorised and certain other payments Schedule 23A Specified Occupations and Professions Schedule 23B Limit on Tax-Relieved Pension Funds Schedule 23C Pre-retirement access to PRSA AVCs Schedule 24 Relief from Income Tax and Corporation Tax by Means of Credit in Respect of Foreign Tax Schedule 24A Arrangements Made by the Government with the Government of any Territory Outside the State in Relation to Affording Relief from Double Taxation and Exchanging Information in Relation to Tax Schedule 24A, Part 1 Arrangements in Relation to Affording Relief from Double Taxation in Respect of the Taxes Referred to in Section 826(1), Made by the Government and Specified in Orders Made by the Government Schedule 24A, Part 2 Arrangements, Pursuant to Section 826(1A) in Relation to Affording Relief from Double Taxation of Air Transport Undertakings and their Employees, Made by the Government and Specified in Orders Made by the Government Schedule 24A, Part 3 Arrangements, Pursuant to Section 826(1B) in Relation to Exchange of Information Relating to Tax and in Relation to Other Matters Relating to Tax Schedule 24A, Part 4 Orders Pursuant to Section 826(1C) in Relation to the Recovery of Tax and in Relation to Other Matters Relating to Tax Schedule 24A, Part 5 Orders Pursuant to Section 826(1E) in Relation to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting Schedule 25 Convention Between the Government of Ireland and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Schedule 25A Exemption from Tax in the Case of Gains on Certain Disposals of Shares Schedule 25B List of Specified Reliefs and Method of Determining Amount of Specified Relief Used in a Tax Year Schedule 25C Determination of Amount of Relief to be Treated as Referable to Specified Reliefs as Respects Relief Carried Forward from Tax Year 2006 to Tax Year 2007 Schedule 26 Replacement of Harbour Authorities by Port Companies Schedule 26A Donations to approved bodies Schedule 26A, Part 1 List of approved bodies for the purposes of section 848A Schedule 26A, Part 2 Approval of a body for education in the arts Schedule 26A, Part 3 Approval of body as eligible charity Schedule 27 Forms of Declarations to be Made by Certain Persons Schedule 27, Part 1 Schedule 27, Part 2 Schedule 28 Statements, Lists and Declarations Schedule 29 Provisions Referred to in Sections 1052, 1054, 1077E and 1077F Schedule 30 Repeals Schedule 31 Consequential Amendments Schedule 32 Transitional Provisions Schedule 33 Specific Anti-Avoidance Provisions for the Purposes of Part 33 Schedule 34 Specified arrangements referred to in section 817RI Schedule 35 Schedule 35A Types and Descriptions of Slurry Storage Items for the Purposes of Section 658A Schedule 35A, Part 1 Definition Schedule 35A, Part 2 Schedule 36 Types and Standards of Concrete Product for the Purposes of Part 18E

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AI Summary of 107. Apportionment of profits.

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Version status: In force | Document consolidation status: Updated to reflect all known changes

Version date: 30 November 1997 - onwards

107. Apportionment of profits.

(1) Where in the case of any profits or gains chargeable under Case I, II or IV of Schedule D it is necessary, in order to determine the profits or gains or losses of any year of assessment or other period, to divide and apportion to specific periods the profits or gains or losses for any period for which the accounts have been made up, or to aggregate any such profits or gains or losses or any apportioned parts of such profits or gains or losses, it shall be lawful to make such division and apportionment or aggregation.

(2) Any apportionment under this section shall be made in proportion to the number of months or fractions of months in the respective periods.

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