Specified Collective Investment Undertaking
15/02/1996
Query
Would investment by Lloyds syndicates, some of whose members are resident in Ireland for tax purposes, prejudice the tax exempt status of the fund?
Decision
No, Lloyds syndicates are regarded as non-resident investors and there is no look through to the individual Lloyds "names".
Income Tax
Section 734, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:5019/96