Links from Section 246 | ||
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Act | Linked to | Context |
Finance Act 2005 |
(d) a common contractual fund within the meaning given to it in section 739I |
|
National Treasury Management Agency (Amendment) Act 2014 |
(ed) interest paid by a Fund investment vehicle (within the meaning of section 37 of the National Treasury Management Agency (Amendment) Act 2014) of which the Minister for Finance is the sole beneficial owner, |
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section 37 |
(ed) interest paid by a Fund investment vehicle (within the meaning of section 37 of the National Treasury Management Agency (Amendment) Act 2014) of which the Minister for Finance is the sole beneficial owner, |
|
Taxes Consolidation Act, 1997 |
(2) Where any yearly interest charged with tax under Schedule D is paid— |
|
Taxes Consolidation Act, 1997 |
(e) interest on any securities in respect of which the Minister for Finance has given a direction under section 36, |
|
Taxes Consolidation Act, 1997 |
(cc) interest paid in the State to a qualifying company (within the meaning of section 110), |
|
Taxes Consolidation Act, 1997 |
(ccc) interest paid by a qualifying company (within the meaning of section 110) to a person who, by virtue of the law of a relevant territory, is resident for the purposes of tax in the relevant territory, except, in a case where the person is a company, where such interest is paid to the company in connection with a trade or business which is carried on in the State by the company through a branch or agency, |
|
Taxes Consolidation Act, 1997 |
the person by or through whom the payment is made shall on making the payment deduct out of the payment a sum representing the amount of the tax on the payment at the standard rate in force at the time of the payment, and subsections (1) and (3) to (5) of section 238 shall apply to such payments as they apply to payments specified in subsection (2) of that section. |
|
Taxes Consolidation Act, 1997 |
“bank” includes building society within the meaning of section 256(1); |
|
Taxes Consolidation Act, 1997 |
(ii) by a company (in this paragraph referred to as the “first-mentioned company”) to which subparagraphs (i) and (ii) of subsection (5)(a) apply to another company resident in the State where that other company is deemed to be a member of the same group of companies as the first-mentioned company and for this purpose the provisions of subsection (1) of section 411 shall apply to determine whether companies are deemed to be members of the same group of companies as if references in that subsection to a 75 per cent subsidiary were references to a 51 per cent subsidiary, |
|
Taxes Consolidation Act, 1997 |
(g) interest which under section 437 is a
|
|
Taxes Consolidation Act, 1997 |
“relevant security” means a security issued by a company
|
|
Taxes Consolidation Act, 1997 |
“relevant security” means a security issued by a company
|
|
Taxes Consolidation Act, 1997 |
(i) the National Asset Management Agency or a company referred to in section 616(1)(g), |
|
Taxes Consolidation Act, 1997 |
(ii) the State acting through the National Asset Management Agency or through a company referred to in section 616(1)(g), or |
|
Taxes Consolidation Act, 1997 |
(iii) the National Treasury Management Agency by the National Asset Management Agency or by a company referred to in section 616(1)(g), |
|
Taxes Consolidation Act, 1997 |
(ii) a company referred to in section 616(1)(g), or |
|
Taxes Consolidation Act, 1997 |
(iii) the State acting through the National Asset Management Agency, or through a company referred to in section 616(1)(g), |
|
Taxes Consolidation Act, 1997 |
(f) interest paid without deduction of tax by virtue of
|
|
Taxes Consolidation Act, 1997 |
(a) a unit trust mentioned in section 731(5)(a), |
|
Taxes Consolidation Act, 1997 |
(ii) by a specified collective investment undertaking within the meaning of section 734, |
|
Taxes Consolidation Act, 1997 |
(b) a special investment scheme within the meaning given to it in section 737,
|
|
Taxes Consolidation Act, 1997 |
(c) an investment undertaking within the meaning given to it in
|
|
Taxes Consolidation Act, 1997 |
(bbb) interest paid in the State to an investment undertaking within the meaning of section 739B, |
|
Taxes Consolidation Act, 1997 |
(d) a common contractual fund within the meaning given to it in section 739I |
|
Taxes Consolidation Act, 1997 |
(e) an investment limited partnership within the meaning of section 739J; |
|
Taxes Consolidation Act, 1997 |
(fa) interest paid in the State to an exempt approved scheme within the meaning of section 774, |
|
Taxes Consolidation Act, 1997 |
(b) not being such a Member State, a territory with the government of which arrangements having the force of law by virtue of
|
|
Taxes Consolidation Act, 1997 |
(c) not being a territory referred to in paragraph (a) or (b), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826(1) will have the force of law; |
|
Taxes Consolidation Act, 1997 |
(A) is exempted from the charge to income tax under arrangements made with the government of a territory outside the State having the force of law under the procedures set out in section 826(1), or |
|
Taxes Consolidation Act, 1997 |
(B) would be exempted from the charge to income tax if arrangements made, on or before the date of payment of the interest, with the government of a territory outside the State, that do not have the force of law under the procedures set out in section 826(1), had the force of law when the interest was paid, |
|
Taxes Consolidation Act, 1997 |
(B) has provided the first company referred to in subsection (3)(bb) with its tax reference number (within the meaning of section 885). |
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Links to Section 246 (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(4A) (a) For the purposes of this subsection “relevant territory” and “tax” have the same meanings as in section 246. |
|
Taxes Consolidation Act, 1997 |
(II) as is a payment from which tax has been deducted at the standard rate in force at the time of the payment in accordance with section 246(2). |
|
Taxes Consolidation Act, 1997 |
(4B) Where any amount, paid out of the assets of a qualifying company under a return agreement, that is dependent on the results of that company’s business or any part of that business, would not be deducted in computing profits or gains of that company if that amount were to be treated, for all the purposes of the Tax Acts, other than subsection (2) of section 246, as a payment of interest, in respect of securities of the company other than specified instruments, that was dependent on the results of the company’s business, then that amount shall not be so deducted. |
|
Taxes Consolidation Act, 1997 |
(ii) a company shall not be chargeable to income tax in respect of interest paid by a relevant person (within the meaning of section 246) in the ordinary course of a trade or business carried on by that person— |
|
Taxes Consolidation Act, 1997 |
(v) a person shall not be chargeable to income tax in respect of discounts arising on securities issued by a relevant person (within the meaning of section 246) in the ordinary course of a trade or business carried on by that person if the first mentioned person is not a resident of the State and is regarded as being a resident of a relevant territory for the purposes of this subsection. |
|
Taxes Consolidation Act, 1997 |
(2) Where a company would not be chargeable to income tax in respect of interest paid in respect of a ‘relevant security’ (within the meaning of section 246) in accordance with this section but for the fact that— |
|
Taxes Consolidation Act, 1997 |
(i) payments made by the company in the accounting period and in respect of which income tax is required to be deducted by virtue
of
|
|
Taxes Consolidation Act, 1997 |
(ii) the tax deducted out of those payments by virtue of
|
|
Taxes Consolidation Act, 1997 |
(ii) that section as applied by section 246, |
|
Taxes Consolidation Act, 1997 |
(II) the interest is interest referred to in paragraph (a), (b) or (h) of section 246(3), or |
|
Taxes Consolidation Act, 1997 |
(c) to which section 238 or 246(2) do not apply by virtue of
|
|
Taxes Consolidation Act, 1997 |
(A) section 246(2) shall not apply to that payment, and |
|
Taxes Consolidation Act, 1997 |
(A) section 246(2) shall not apply to that payment, and |
|
Taxes Consolidation Act, 1997 |
(3) Any payment of relevant interest which is within subsection (1) shall be treated as not being within section 246. |
|
Taxes Consolidation Act, 1997 |
(3) Section 246(2) does not apply to a payment of specified interest if it would otherwise apply. |
|
Taxes Consolidation Act, 1997 |
(1) Where, apart from this section, section 238, 246(2) or 257 would apply to a payment of interest or royalties to which this Chapter applies, those sections shall not apply to that payment. |
|
Taxes Consolidation Act, 1997 |
(3) This section shall not apply to any sum assessed under section 238 by virtue of section 246(2), 757 or 1041(1). |
|
Taxes Consolidation Act, 1997 |
then, subject to subsections (5) to (7), the payment shall be made without deduction of income tax and neither section 238 nor section 246 shall apply to the payment. |
|
Taxes Consolidation Act, 1997 |
“territory” means a territory other than a relevant territory within the meaning of section 246. |
|
Taxes Consolidation Act, 1997 |
(2) Section 246(2) shall not apply to interest paid on any quoted Eurobond where— |
|
Taxes Consolidation Act, 1997 |
(II) neither the stock seller nor the stock buyer would be entitled to receive a payment of interest without deduction of tax under section 246 and, where such tax is deducted, neither the stock seller nor the stock buyer would be entitled to a repayment of any such tax withheld or any part thereof. |
|
Taxes Consolidation Act, 1997 |
“relevant interest” means interest to which subsection (2) of section 246 does not apply by virtue only of paragraph (h) (inserted by the Finance Act, 1999) of subsection (3) of that section; |
|
Taxes Consolidation Act, 1997 |
“relevant person” has the same meaning as in section 246; |