Distributions to certain non-resident companies
06/10/1994
Query
Ireland/Luxembourg Double Taxation Convention and section 168 of the Taxes Consolidation Act, 1997 (s.47 Finance Act, 1983) question of exemption from ACT of a Luxembourg holding company
Decision
Luxembourg holding companies are entitled to the exemption from ACT under section 168 Taxes Consolidation Act, 1997 (s.47 Finance Act, 1983)
Corporation Tax
Section 168, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:DTX 7052/94