Universitiies
15/07/1996
Query
Whether payments for the construction of a Library Information Technology Services Building qualify for relief under sections 767, 792, and 763 TCA 1997. Section 767 allows tax relief for payments to universities and other approved bodies for research in, or teaching of, approved subjects. Section 792 allows tax relief for payments to a University or college in the State for the purpose of enabling that university or college to carry on research. Section 764 allows a deduction in computing profits for payment to an Irish university or orther body approved by the Minister for Finance in order that such university or body may undertake scientific research. The point at issue was whether payments made to fund the construction of a Library Information Technology Services Building would qualify for relief under the sections. The building in question would be used by students studying approved subjects and by post-graduates carrying on scientific research.
Decision
To the extent that the library building was used in connection with purposes which qualify under the various sections, relief would be given in respect of payments made under that section and applied towards the cost of the library building. Relief would not be given more than once for any payment. In determining whether a relief applies to a payment and if so which relief, the inspector will look at the extent of the use of the building for the purpose specified in the particular section and how the payment was applied.
Income Tax
Section 767, Taxes Consolidation Act, 1997
Origin: RLS Division
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