Revenue Documents

Dividend Stripping (S.621, S.622)

Covers treatment of dividend stripping under TCA 1997 sections 621-622, where distributions materially reduce shareholding value. Explains how dividend stripping is treated as depreciatory transactions and loss disallowance mechanisms. Critical for understanding anti-avoidance rules affecting group shareholdings.

Shares in subsidiary - Group relief protection (S.625)

Details anti-avoidance provision under TCA 1997 section 625 preventing tax-free exit of subsidiaries from groups. Covers use of reconstruction/amalgamation provisions to avoid charges under section 617. Relevant to corporate restructurings and group reorganizations.

Company Ceasing to be Member of Group (S.623)

This document explains the tax charge under section 623 TCA 1997 when a company leaves a group of companies. It covers the scope of the charge, exceptions, withdrawal of section 617 relief, timing of tax liability, and special provisions for patents and CGT-chargeable companies. Tax consultants use this to advise on group restructuring and the exit tax implications for departing group members.

Section 624 TCA 1997: Exemption from S.623 in Mergers

This document details the conditions under section 624 TCA 1997 that exempt companies from the section 623 charge when leaving a group as part of a bona fide commercial merger. It outlines the definition of qualifying mergers, conditions for exemption (commercial purpose, not tax avoidance), and application to non-resident companies. Tax advisors reference this when structuring merger transactions to avoid exit tax charges.

Exemption from tax on certain share disposals (S.626B)

Provides exemption from CGT under TCA 1997 section 626B for gains on disposal of subsidiary shareholdings meeting specific conditions. Covers shareholding requirements, investee company residence, and trading conditions. Essential for corporate investors and holding companies.

Treatment of assets related to shares (S.626C)

Explains CGT exemption under TCA 1997 section 626C for assets related to shares in other companies, parallel to section 626B. Covers conditions where related assets qualify for exemption and group member provisions. Complements section 626B for broader holding company relief.

Recovery of tax from group members (S.626)

Empowers Revenue to recover unpaid CT on chargeable gains from group members under TCA 1997 section 626. Covers recovery from principal company or asset-owning members, 6-month unpaid tax threshold, and 2-year assessment period. Important for understanding group liability and payment obligations.

Residential Development Land - 20% tax rate (S.644A, S.644B)

Historically addressed 20% effective tax rate on residential development land income under TCA 1997 sections 644A (income tax) and 644B (corporation tax). Document note indicates provisions were terminated by Finance Act 2009, making this guidance no longer applicable.

Exit Tax Provisions (S.627-629C TCA 1997)

This comprehensive guide covers the exit tax regime under sections 627 to 629C TCA 1997, which charges tax when companies cease to be Irish resident or transfer assets abroad. It details chargeable events, the calculation of exit tax, exclusions (including roll-over relief), treatment of losses, and interaction with other reliefs. Essential for tax professionals advising on corporate emigration and asset transfers out of Ireland.

Part 22-01-03

Tax and Duty Manual document on corporation tax matters. Document content not available in excerpt.

TCA Section 22-02-01 - Income Tax, CGT & Corporation Tax

Guidance document covering section 22-02-01 relating to Income Tax, Capital Gains Tax, or Corporation Tax matters under the Taxes Consolidation Act 1997. Provides reference material for tax professionals on specific tax provisions.

Companies Chargeable to CGT on Development Land (S.649)

Explains how companies are charged to Capital Gains Tax rather than Corporation Tax on gains from disposals of development land under section 649 TCA 1997. Covers the application of CGT rules to company groups and payment date determination. Essential for tax professionals advising companies on development land transactions and the interaction between CGT and CT treatment.

Development Land: Rate of Charge (S.649A)

Details the tax rates applicable to development land disposals under section 649A TCA 1997, covering the 40% rate for disposals between 3 December 1997 and 30 November 1999, and the 33% rate for disposals from 6 December 2012 onwards. Includes exceptions for planning decisions, compulsory purchases, holiday cottages, and NAMA Act applications.

Windfall Gains from Rezonings: Rate of Charge (S.649B)

Addresses the taxation of windfall gains arising from relevant planning decisions (rezonings) under section 649B TCA 1997, including the application of an 80% rate on gains attributable to planning changes. Covers relevant periods, anti-avoidance rules, losses, exceptions, and NAMA legislation implications.

Residential Zoned Land Tax (Part 22A TCA 1997)

Comprehensive guidance on the Residential Zoned Land Tax (RZLT) under Part 22A of the Taxes Consolidation Act 1997. Covers what land qualifies, serviced land definitions, liable persons, liability and valuation dates, local authority map procedures, registration, payment, administration, and annual revision timelines. Updated January 2026. Essential for advisers on residential development and vacant land taxation.

RZLT Site Registration Guidelines (Part 22A-01-02)

Operational guidelines for registering residential zoned land tax sites under Part 22A TCA 1997. Covers ROS and myAccount customer registration processes, multi-owner sites, agent registration, planning permission scenarios, and pay and file obligations. Updated August 2025. Provides step-by-step registration procedures for tax professionals and liable persons.

RZLT Site Sale or Transfer Guidelines (Part 22A-01-03)

Guidelines on sale and transfer of residential zoned land tax sites under Part 22A TCA 1997. Addresses ROS and myAccount filing procedures, group company transfers, payment processing, and site sale documentation. Updated August 2025. Essential for advisers handling RZLT site transactions and liability discharge.

RZLT Return Guidelines (Part 22A-01-04)

Operational guidelines for filing Residential Zoned Land Tax returns under Part 22A TCA 1997. Covers ROS and myAccount return completion procedures, agent filing, rezoning submissions, pay and file obligations, and 2025 map updates. Updated August 2025. Provides detailed instructions for annual RZLT return filing and compliance.

Vacant Homes Tax (Part 22B TCA 1997)

Guidance on Vacant Homes Tax (VHT) under Part 22B of the Taxes Consolidation Act 1997. Covers scope of VHT on residential properties, exemptions, 30-day occupancy threshold, chargeable persons, filing and payment obligations, and property status confirmation. Updated December 2024. Essential for property owners and advisers managing residential properties.

Farm Loss Relief Restriction (S.662)

Guidance on restrictions to loss relief claims in farming or market gardening. Relevant for farmers with losses subject to income tax relief limitations.

Farm Buildings Allowances (S.658)

Details capital allowances available for farm building investments. Applies to farmers claiming allowances on qualifying farm building expenditure.

Farming: Death Cases - Commencement/Cessation (TCA Part 23)

Outlines the tax treatment when a spouse continues farming activities following the death of their spouse, including relief from normal cessation and commencement provisions. Covers averaging, stock relief elections, and conditions for qualifying successors under TCA Part 23 Chapter 1.

Bloodstock Valuation of Foals

Guidance on how to value foals as trading stock for tax purposes. Relevant for bloodstock traders and those engaged in farming/stud operations, covering the components of foal valuation including stud fees and nomination costs.

Taxation of Farm Payments: Basic Payment Scheme

Explains the income tax treatment of EU agricultural payments under the Basic Payment Scheme (BPS), including greening payments, young farmer payments, and voluntary coupled support. Covers basis of accounting, receipts versus earnings basis, and treatment of payments for active farmers.

Relief for Farmland Leasing Income

Explains tax relief available for certain income derived from leasing farmland. Applies to farmers and landowners who lease agricultural property, under TCA section 664.

Share Farming: Income Tax and VAT Treatment

Comprehensive guide to the tax and VAT treatment of share farming arrangements where two parties operate separate businesses on the same land. Covers income tax treatment of basic payment scheme and agri-environmental payments, livestock transactions, stock relief, and VAT implications for crop and livestock sales.

Corporation Tax Loss Relief in Farming

Details the restriction on corporation tax relief for losses incurred in farming or market gardening operations. Relevant for corporate entities engaged in agricultural activities, under TCA section 663.

Farming: Spouse Trading in Partnership

Addresses tax treatment when spouses trade together in a farming partnership. Relevant for married couples operating farms as partnerships, covering TCA Part 23 Chapter 1 provisions.

Averaging of Farm Profits

Explains the mechanism for averaging farm profits across multiple years to reduce tax volatility. Applicable to farmers seeking to smooth taxable income, under TCA section 657.

Research and Development Credit: Payment of Excess (S.766, 766A)

Details the rules for payment of excess R&D credits under sections 766 and 766A TCA 1997 at the 25% rate, including carryback provisions, payable credit limits, and Covid-19 related changes. Covers time limits for R&D claims and interaction with section 766B aggregate limits.

TCA Part 23-01-36

Revenue guidance document on farming and agricultural tax matters. Content details not available from current extract.

TCA Part 23-01-37

Revenue guidance document on farming and agricultural tax matters. Content details not available from current extract.

Stock Relief for Young Trained Farmers

Covers stock relief provisions specifically available to young trained farmers as an incentive for agricultural investment. Applies to eligible farmers under TCA sections 654A and 667B.

Stock Relief – Farming Trades

Explains stock relief available to farmers engaged in farming trades, allowing relief on increases in trading stock value. Relevant for all farming operations, under TCA section 666.

TCA Part 23-02-07

Revenue guidance document on farming and agricultural tax matters. Content details not available from current extract.

Tax Treatment of Animal Leasing

Details the tax treatment of leasing arrangements involving animals in farming contexts. Relevant for farmers and animal lessors, under TCA Part 23.

Research and Development Credit: Clawback of Relief (S.766, 766A, 766B)

Explains the clawback procedures when R&D relief is claimed but subsequently found to be improperly due under sections 766, 766A and 766B TCA 1997. Covers Schedule D Case IV assessments, change of use of buildings, interest on excessive claims, and penalties under section 1077E.

Deed of Covenant

Covers the tax treatment of Deeds of Covenant, which are legally binding written agreements to pay agreed amounts to another person, under Part 31 Chapter 1 TCA 1997. Provides guidance on when deeds of covenant apply and their tax implications.

Tax Credit for Succession Farm Partnerships

Explains the tax credit available on succession in farm partnerships, designed to facilitate intergenerational transfer of farming operations. Applies under TCA section 667D.

TCA Part 23-05-01

Revenue guidance document on farming and agricultural tax matters. Content details not available from current extract.

Petroleum Production Tax (S.696G-696M)

This document provides operational guidance on Petroleum Production Tax (PPT) under sections 696G to 696M TCA 1997, a tax on upstream petroleum extraction. It covers PPT calculation including the R Factor, interaction with corporation tax and profit resource rent tax, valuation of petroleum assets, group treatment, returns, and payment procedures. Relevant for oil and gas companies and their advisors managing petroleum extraction in Irish waters.

Tonnage Tax (Part 24A TCA 1997)

Comprehensive guidance on Tonnage Tax under sections 697A to 697Q and Schedule 18B TCA 1997. Covers company qualification, strategic management of qualifying ships, election procedures, tonnage tax activities, profit calculation, capital allowances, loss treatment, and relief provisions. Updated January 2026. Relevant for shipping companies and maritime industry professionals.

Temporary Solidarity Contribution (Part 24B TCA 1997)

Guidance on Temporary Solidarity Contribution under Part 24B TCA 1997 and the Energy (Windfall Gains in the Energy Sector) Act 2023. Covers taxable profits calculation, capital expenditure treatment, loss restrictions, average profit calculations, contribution rates, and deductibility for Corporation Tax purposes. Updated August 2025. Relevant for energy sector companies subject to windfall gains taxation.

Tax Treatment of Credit Union Bonus Shares

Clarifies the tax treatment of bonus shares issued by credit unions. Relevant to credit union members receiving bonus share distributions, under TCA section 698.

Industrial and Provident Societies: Expense Deductions

Explains deduction of certain sums and expenses for industrial and provident societies. Relevant for such societies, under TCA sections 396 and 699.

Special Computational Provisions: IPS

Details special computational rules for calculating taxable income of industrial and provident societies. Applicable to all such societies, under TCA section 700.

Share Transfer: Society Members

Explains tax treatment of share transfers from societies to members. Relevant to members of industrial and provident societies receiving share distributions, under TCA section 701.

Real Estate Investment Trusts (REITs) - TCA Part 25A

Comprehensive guide to the tax regime for Real Estate Investment Trusts (REITs) covering conditions for REIT status, taxation of REITs and their shareholders, and annual reporting requirements. Covers sections 705B through 705M of TCA 1997. Essential for property investment companies, fund managers, and tax advisors handling REIT structures and property rental income.

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TCA Part 26-01-02

Revenue guidance document on tax matters. Content details not available from current extract.

IFRS Implications for Life Assurance Business

Analyzes the impact of International Financial Reporting Standards on the taxation of life assurance companies' new basis business. Relevant to life insurers adopting IFRS accounting.

Life Assurance Exit Tax Repayment – Non-Residents

Sets out entitlement to repayment of exit taxes for non-resident life policy holders who were resident when policies were entered. Relevant to non-resident policyholders under TCA Part 26, Chapter 5.

Life Assurance Companies - Return of Payments

Guidance on reporting requirements for life assurance companies under Section 891B TCA 1997. Relevant for insurance undertakings filing returns of payments to policyholders and investors.

Part 27-01-01

Document reference 27-01-01 with no text content available. Appears to be part of Part 27 guidance on investment funds and overseas funds taxation.

Taxation of 'Net' Funds

Guidance on the taxation treatment of net funds under Section 738 TCA 1997. Relevant for investors and fund managers dealing with net fund structures and their tax implications.

Part 27-01A-02

Document reference 27-01A-02 with no text content available. Likely covers investment fund taxation sub-topic under Part 27.

Part 27-01A-03

Document reference 27-01A-03 with no text content available. Likely covers investment fund taxation sub-topic under Part 27.

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Part 27-01B-02

Document reference 27-01B-02 with no text content available. Likely covers investment fund taxation sub-topic under Part 27.

Part 27-02-01

Document reference 27-02-01 with no text content available. Appears to be foundational guidance on offshore funds taxation under Part 27.

Part 27-02B-01

Document reference 27-02B-01 with no text content available. Likely covers offshore funds taxation sub-topic under Part 27.

Offshore Funds: EU, EEA & OECD Taxation

Guidance on taxation of income and gains from offshore funds established in EU, EEA and OECD member states under Part 27 TCA 1997. Relevant for investors with international fund holdings.

Offshore Funds - Irish-Managed with Agent

Guidance on taxation of offshore funds managed in Ireland using independent authorised resident agents under Chapter 5 Part 27 TCA 1997. Applies to fund managers and investors in Ireland-managed offshore structures.

Return of Values - Investment Undertakings

Reporting requirements for investment undertakings under Section 891C TCA 1997. Relevant for fund managers and investment companies filing returns of investment values.

Allowances for Scientific Research

Guidance on capital allowances for scientific research expenditure under Section 765 TCA 1997. Relevant for companies and sole traders claiming R&D related capital deductions.

Research & Development Corporation Tax Credit

Guidance on the R&D tax credit scheme under Sections 766-766D TCA 1997. Relevant for companies undertaking qualifying research and development activities claiming corporation tax credits.

R&D Corporation Tax Credit (S.766C, 766D, 766A)

This document provides operational guidance on the Research and Development (R&D) Corporation Tax Credit under sections 766C, 766D, 766(4D), and 766A(4C) TCA 1997. It explains eligibility criteria, calculation of the credit, qualifying expenditure, and application procedures. This guidance has been consolidated into TDM Part 29-02-03. Tax professionals use this to advise companies on claiming R&D tax credits on qualifying research and development activities.

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R&D Corporation Tax Credit - Expert Audit Appointment (TCA s.766)

Procedural guidance on appointing independent experts to assist with Research and Development (R&D) Corporation Tax Credit audits. Covers the formation of expert panels, appointment processes, timing requirements, and expert briefing procedures under sections 766-766D of TCA 1997. Relevant for Revenue officials, R&D units, and companies undergoing R&D credit audits.

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Religious Community Members - Covenanted Income

Guidance on taxation of income covenanted between members of religious communities. Covers the High Court decision in Revenue Commissioners v. HI regarding covenant deeds and tax treatment.

Part 32-02-01

Document reference 32-02-01 with no text content available. Likely covers part of income tax or other tax relief provisions.

Main Purpose Tests

Guidance on main purpose test requirements under Part 33 TCA 1997. Applies to tax avoidance provisions and transactions subject to purpose-based anti-avoidance rules.

Scrip Dividends - Share Option in Lieu

Guidance on tax treatment of scrip dividends (options to acquire shares in lieu of cash distributions) under Section 816 TCA 1997. Relevant for shareholders and companies offering dividend alternatives.

Tax Treatment of Employee Benefit Schemes

Comprehensive guidance on tax treatment of various employee benefit arrangements. Relevant for employers, employees, and scheme administrators on tax implications of benefits.

General Anti-Avoidance Rule (GAAR) & Notifications

Guidance on the General Anti-Avoidance Rule (GAAR) under Sections 811C and 811D TCA 1997 and protective notification procedures. Essential for tax planning compliance and avoidance risk mitigation.

Mandatory Disclosure Guidance Notes

Guidance on mandatory disclosure of reportable transactions under Part 33 Chapter 3 TCA 1997. Applies to promoters and taxpayers using tax planning arrangements that must be disclosed.

Transfer Pricing Documentation

Guidance on transfer pricing documentation requirements and compliance obligations under Irish tax law. Relevant for multinational enterprises and groups conducting cross-border transactions.

DAC6 Mandatory Disclosure Compliance

Compliance guidance for the EU DAC6 directive on mandatory disclosure of reportable cross-border tax arrangements. Essential for tax advisors, intermediaries, and taxpayers involved in cross-border transactions.

Tax Avoidance Schemes - Reporting

Guidelines on reporting and disclosure requirements for tax avoidance schemes. Applicable to promoters and users of potentially avoidable tax arrangements.

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Outbound Payments Defensive Measures

Guidance on defensive measures for outbound payments including withholding obligations and anti-avoidance provisions. Relevant for companies making payments to non-residents.

Residence of Individuals - Key Provisions

Comprehensive guidance on determining the Irish tax residence status of individuals under TCA Part 34. Essential for individuals with multi-jurisdictional connections.

Trust and Estate Residence Rules

Guidelines for determining the tax residence of trusts (excluding unit trusts) and estates under administration, with specific reference to UK comparisons. Relevant for trustees and estate administrators.

Transborder Workers Relief

Guidance on transborder workers relief provisions for employees working across borders. Applicable to cross-border commuters and expatriate workers.

Foreign Earnings Deduction (Section 823A)

Guidance on the foreign earnings deduction allowing relief for income earned in certain foreign states. Relevant for employees and individuals with foreign-sourced income.

Special Assignee Relief Programme (SARP)

Guidance on SARP, a tax relief scheme for assignees working in Ireland. Applicable to individuals on employment assignments in Ireland.

Split Year Residence Elections

Guidance on split year residence treatment allowing individuals to claim different residence status in arrival/departure years. Relevant for individuals moving to or from Ireland.

Foreign Tax Credit & Relief Provisions

Overview of foreign tax credit and relief mechanisms under Irish tax law. Applicable to individuals and companies with foreign tax liabilities.

Double Tax Treaty Administration

Administrative guidance on double tax treaty implementation and relief procedures. Essential reference for tax practitioners managing cross-border tax affairs.

Ireland/UK DTA Certificate Forms

Guidance on certification of tax residency forms (Form IRL-Individual and Form Ireland-Company) under the Ireland-UK double taxation agreement. Required for individuals and companies claiming treaty benefits.

OECD Model Treaty Provisions

Reference guide to OECD Model Tax Convention provisions and their application in Irish treaty practice. Relevant for understanding treaty principles and interactions.

Foreign Royalty Tax Certification (IMRO)

Guidance on IMRO certification of tax deducted on foreign royalties and consolidated certificates of foreign royalty income and tax credits. Applicable to Irish music/entertainment entities receiving royalties.

Interest Distribution to Treaty Residents

Guidance on tax treatment of interest payments to residents of tax treaty countries and EU member states. Relevant for companies paying interest to foreign residents.

Ireland-Estonia DTA Royalty Treatment

Guidance on revised royalty income tax treatment under the Ireland-Estonia double taxation convention effective 1 January 2016. Applicable to royalty payments between Ireland and Estonia.

Ireland-Chile DTA Interest & Royalty

Guidance on revised interest and royalty income tax treatment under the Ireland-Chile double taxation convention effective 1 January 2017. Applicable to interest and royalty payments between Ireland and Chile.

Ireland-Malta DTA Competent Authority

Guidance on the Competent Authority Agreement between Ireland and Malta under the double taxation convention mutual agreement procedure. Relevant for resolving double taxation disputes between the countries.