Revenue eBrief No. 105/17

20 November 2017

Distributions out of certain exempt profits or gains or out of certain relieved income

The Revenue Tax and Duty Manuals Parts 06-04-02 (Distributions out of certain exempt profits or gains or out of certain relieved income) and 06-06-01 (Section 154 TCA 1997 - Attribution of Distributions to Accounting Periods) have been updated. Both manuals deal, among other things, with the treatment of certain types of income which is, or was, exempted income.

Over time, a number of exemptions given in respect of certain income have been withdrawn. The exemptions of certain profits derived from stallion fees (s231 Taxes Consolidation Act 1997), stud greyhound services (s233 TCA 97), and income from patent royalties (s141 TCA 97) are no longer available.

 A paragraph has been inserted in Manual Part 06-04-02 to bring attention to the fact that the exemptions referred to in the manual may not be of current relevance.

 Manual Part 06-06-01 refers to section 154 Taxes Consolidation Act 1997, which allows for certain distributions to be attributed to certain accounting periods. This manual has been updated to draw attention to the fact that some of the income sources mentioned are no longer treated as being exempt. It may also be noted that Manufacturing Relief and Export Sales Relief are mentioned in the manual; both of these reliefs have been discontinued.