Amended manuals have been released by Revenue, to provide clarifications on exemptions for compensation payments in respect of personal injuries and special trusts for incapacitated individuals.

Revenue have amended the tax and duty manuals:

• Compensation payments in respect of personal injuries (exemption of investment income), and
• Special trusts for permanently incapacitated individuals

to provide clarification on the interaction of the exemptions provided for under section 189 and section 189A TCA 1997.

Included within the manuals is confirmation of Revenue’s view that, subject to conditions being met, “relevant income” and/or “relevant gains” arising under section 189 TCA 1997 is not included as “total income and gains” when applying the 50% test for section 189A TCA 1997, and vice versa.