Computer Hardware
20/10/1992
Query
Does the customisation of systems -- not always made in Ireland, but where intergration takes place in Ireland, qualify for the 10% rate. Does a 90% subsidiary selling the goods of a resident manufacturing company have to be resident in the state to qualify for manufacturing relief. .
Decision
Allowed - only a small element of turnover arose from non Irish systems. . No.
Corporation Tax
Section 443, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:821/92
28/10/1992
Query
Does manufacturing relief apply to the verification of integrated circuits: The process results in a Classification which is encoded onto each component . The equipment used in the process resembles an automated assembly line.
Decision
Allowed.
Corporation Tax
Section 443, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:1810/92
26/07/1993
Query
Do the following qualify for manufacturing relief:1Assembly of P.C,s from bought in components. 2.Bought in peripherals i.e. printers and monitors. .
Decision
1.Yes. 2,Allow provided (a) they are built in to the manufactured product , or (b) sold as part of an integrated package and tested by the 10% company ..
Corporation Tax
Section 443, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:1595/93
23/12/1994
Query
Does manufacturing relief apply to the sale of software developed by a software developer and sold embedded in bought in hardware. In the particular case the provision of the hardware is ancillary to the sale of the software package and by far the greater portion of the income derives from the software.
Decision
Allowed.
Corporation Tax
Section 443, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:6448/94