Temporary Solidarity Contribution (TSC)

The TSC applied to surplus profits of energy companies with activities in:

• the extraction, mining or refining of petroleum, natural gas or coal
• or
• the manufacture of coke products.

The TSC applied to taxable profits in the calendar years 2022 and 2023. The TSC was allowed as a deduction in calculating the amount of Corporation Tax (CT) due.

The relevant legislation is contained in the Energy (Windfall Gains in the Energy Sector) (Temporary Solidarity Contribution) Act, 2023. This legislation inserted Part 24B into the Taxes Consolidation Act (TCA), 1997.

How is the TSC calculated?

The TSC applied if the taxable profits for 2022 and, or 2023 exceeded the average taxable profits for 2018 to 2021 by 20%. The amount of TSC due was calculated using the following formula: (A – (B x 1.2)) x 0.75, where:

• (A) was the taxable profits for 2022 and, or 2023
• and
• (B) was the average taxable profits for 2018 to 2021.

The definition of taxable profits used for the purposes of the TSC calculation is provided for in Part 24B of the TCA, 1997.

Registering for the TSC

Energy companies were required to register for the TSC with Revenue on, or before, 30 August 2023. To register for the TSC, energy companies had to complete Form TSC1 and submit it through MyEnquiries in the Revenue Online Service (ROS).

Where a company became an energy company during 2023, the company should have registered on, or before, 30 August 2024.

Pay and file

Energy companies should have completed and filed a return (Form TSC2–2022) for 2022 on, or before, 23 September 2023. Returns in respect of 2023 (Form TSC2) should have been completed and filed on, or before, 23 September 2024. 

The return due had to be submitted through MyEnquiries in ROS. The TSC was due and payable at the same time the return was filed and the payment had to be made through ROS.

Please see Tax and Duty Manual Part 24B-01-01 for further information and guidance on the operation of the TSC.

Note

The Energy (Windfall Gains In the Energy Sector) (Temporary Solidarity Contribution) Act, 2023, transposes Council Regulation (EU) 2022/1854 of 6 October 2022 on an emergency intervention to address high energy prices.