Links from Section 420 | ||
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Act | Linked to | Context |
Finance Act, 2000 |
(9) (a) References in the preceding subsections to a surrendering company shall not include references to a company carrying on life business except to the extent that such life business is new basis business within the meaning of section 730A (inserted by the Finance Act, 2000). |
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Taxes Consolidation Act, 1997 |
(b) so as to reduce the profits of a claimant company which carries on life business (within the meaning of section 706) by an amount greater than the amount of such profits (before a set off under this subsection) computed in accordance with Case I of Schedule D and section 710(1). |
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Taxes Consolidation Act, 1997 |
(2) Where for any accounting period any capital allowances are to be made to the surrendering company which are to be given by discharge or repayment of tax or in charging its income under Case V of Schedule D and are to be available primarily against a specified class of income, so much of the amount of those capital allowances (exclusive of any carried forward from an earlier period) as exceeds its income of the relevant class arising in that accounting period (before deduction of any losses of any other period or of any capital allowances) may be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period. |
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Taxes Consolidation Act, 1997 |
(3) Where for any accounting period the surrendering company (being an investment company) may under section 83(2) deduct any amount as expenses of management disbursed for that accounting period, so much of that amount (exclusive of any amount deductible only by virtue of section 83(3)) as exceeds the company’s profits of that accounting period may be set off for the purposes of corporation tax against the total profits of the claimant company (whether an investment company or not) for its corresponding accounting period. |
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Taxes Consolidation Act, 1997 |
(3) Where for any accounting period the surrendering company (being an investment company) may under section 83(2) deduct any amount as expenses of management disbursed for that accounting period, so much of that amount (exclusive of any amount deductible only by virtue of section 83(3)) as exceeds the company’s profits of that accounting period may be set off for the purposes of corporation tax against the total profits of the claimant company (whether an investment company or not) for its corresponding accounting period. |
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Taxes Consolidation Act, 1997 |
(4) The surrendering company’s profits of the period shall be determined for the purposes of subsection (3) without any deduction under section 83 and without regard to any deduction to be made in respect of losses or allowances of any other period. |
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Taxes Consolidation Act, 1997 |
(5) References in subsections (3) and (4) to section 83 shall not include references to that section as applied by section 707 to companies carrying on life business. |
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Taxes Consolidation Act, 1997 |
(7) The surrendering company’s profits of the period shall be determined for the purposes of subsection (6) without regard to any deduction to be made in respect of losses or allowances of any other period or to expenses of management deductible only by virtue of section 83(3). |
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Taxes Consolidation Act, 1997 |
(1) Where in any accounting period the surrendering company has incurred a loss, computed as for the purposes of section 396(2), in carrying on a trade in respect of which the company is within the charge to corporation tax, the amount of the loss may be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period; but this subsection shall not apply— |
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Taxes Consolidation Act, 1997 |
(a) to so much of a loss as is excluded from section 396(2) by section 396(4) or 663, or |
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Taxes Consolidation Act, 1997 |
(a) to so much of a loss as is excluded from section 396(2) by section 396(4) or 663, or |
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Taxes Consolidation Act, 1997 |
(8) In applying any of the preceding subsections in the case of a claim made by a company as a member of a consortium, only a fraction of the loss referred to in subsection (1), or of the excess referred to in subsection (2), (3) or (6), as the case may be, may be set off under the subsection in question, and that fraction shall be equal to that member’s share in the consortium, subject to any further reduction under section 422(2). |
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Taxes Consolidation Act, 1997 |
(a) to so much of a loss as is excluded from section 396(2) by section 396(4) or 663, or |
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Taxes Consolidation Act, 1997 |
(b) so as to reduce the profits of a claimant company which carries on life business (within the meaning of section 706) by an amount greater than the amount of such profits (before a set off under this subsection) computed in accordance with Case I of Schedule D and section 710(1). |
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Taxes Consolidation Act, 1997 |
(b) For the purposes of this section “life business” shall be construed in accordance with section 706(1). |
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Taxes Consolidation Act, 1997 |
(5) References in subsections (3) and (4) to section 83 shall not include references to that section as applied by section 707 to companies carrying on life business. |
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Taxes Consolidation Act, 1997 |
(b) so as to reduce the profits of a claimant company which carries on life business (within the meaning of section 706) by an amount greater than the amount of such profits (before a set off under this subsection) computed in accordance with Case I of Schedule D and section 710(1). |
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Taxes Consolidation Act, 1997 |
(9) (a) References in the preceding subsections to a surrendering company shall not include references to a company carrying on life business except to the extent that such life business is new basis business within the meaning of section 730A (inserted by the Finance Act, 2000). |
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Links to Section 420 (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(b) in the case of a company, sections 243, 308(4) and 396(2) and subsections (1), (2) and (6) of section 420. |
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Taxes Consolidation Act, 1997 |
(c) the total amount of the loss referred to in subsection (1) of section 420 for the chargeable period and the total amount of the excess referred to in subsection (2), (3) or (6) of that section for that period shall each be treated for the purposes of Chapter 5 of Part 12 as reduced by 50 per cent, |
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Taxes Consolidation Act, 1997 |
(2) In computing the corporation tax chargeable for any accounting period of a company, any charges on income paid by the company in the accounting period, in so far as paid out of the company’s profits brought into charge to corporation tax, shall be allowed as deductions against the total profits for the period reduced by any other relief from corporation tax other than group relief in accordance with section 420. |
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Taxes Consolidation Act, 1997 |
(5) Sections 305(1)(b), 308(4) and 420(2) shall not apply in relation to capital allowances— |
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Taxes Consolidation Act, 1997 |
(II)sections 308(4) and 420(2) shall apply, |
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Taxes Consolidation Act, 1997 |
(b) Sections 305(1)(b), 308(4) and 420(2) shall not apply in relation to capital allowances— |
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Taxes Consolidation Act, 1997 |
such that the aggregate of the amounts of the lease payments which are payable, or which would be payable if the relevant lease payments were the actual amounts payable under the lease, after any time exceeds the aggregate of the amounts of such relevant lease payments which would have been payable after that time if the events in subparagraph (i) or (ii) had not taken place, then, notwithstanding subsection (6)(a), unless it is shown that the change or the termination was effected for bona fide commercial reasons, the lease (including the terminated lease) shall be treated as if it were at all times a relevant lease, and relief given under Part 9, Chapter 1 or 2 of this Part, or section 396 or 420, which would not have been given if the lease was a relevant lease, shall be withdrawn. |
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Taxes Consolidation Act, 1997 |
(II) the amount of any loss which was set off under section 307, 308, 396 or 420 against profits, or |
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Taxes Consolidation Act, 1997 |
(a) sections 305(1)(b), 308(4) and 420(2) shall not apply as respects that allowance, and |
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Taxes Consolidation Act, 1997 |
Where a person incurs capital expenditure of the type to which subsection (7) of section 284 applies and an allowance is to be made in respect of that expenditure under that section, sections 305(1)(b), 308(4) and 420(2) shall not apply as respects that allowance. |
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Taxes Consolidation Act, 1997 |
(ii) against the total profits of a claimant company under section 420(1), except to the extent of the amount of income from a qualifying shipping trade included in those total profits, |
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Taxes Consolidation Act, 1997 |
(2) Notwithstanding subsections (1) and (6) of section 420 and section 421, where in any accounting period the surrendering company incurs a relevant trading loss or an excess of relevant trading charges on income, that loss or excess may not be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period. |
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Taxes Consolidation Act, 1997 |
(a) corresponds to an amount of a kind that, for the purposes of section 420 or 420A, could be available for surrender by means of group relief by a company resident in the State, |
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Taxes Consolidation Act, 1997 |
(2) Group relief in accordance with section 420 for an accounting period shall be allowed as a deduction against the claimant company’s total profits for the period before reduction by any relief derived from a subsequent accounting period, but as reduced by any other relief from tax (including relief in respect of charges on income under section 243(2)). |
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Taxes Consolidation Act, 1997 |
(a) references in section 420 to accounting periods, to profits, and to losses, allowances, expenses of management or charges on income of the surrendering company, shall be construed in accordance with subsection (2); |
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Taxes Consolidation Act, 1997 |
(20) (a) Notwithstanding subsections (1) and (6) of section 420 and section 421, where in an accounting period ending before 31 December 2009 the surrendering company has incurred a loss in a trade, the operations or activities of which consist of or include dealing in residential development land, then an amount of the loss, determined in accordance with paragraph (b), may not be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period. |
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Taxes Consolidation Act, 1997 |
(b) subject to subsection (4)(b)(ii), shall not otherwise be entitled to relief in respect of the loss or to surrender relief under section 420(1) in respect of the loss. |
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Taxes Consolidation Act, 1997 |
then, for the purpose of enabling the company to surrender the excess referred to in paragraph (a) by means of group relief, section 420(6) shall apply as if— |
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Taxes Consolidation Act, 1997 |
(2) Where relief in respect of interest paid, being interest treated as a charge on income, is claimed by virtue of section 420(6), any question under this section as to what benefit might be expected to accrue from the transaction under which that interest is paid shall be determined by reference to the claimant company (within the meaning of section 411(2)) and the surrendering company (within the meaning of that section) taken together. |
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Taxes Consolidation Act, 1997 |
(3) The amount of any expenditure to be treated under subsection (2) as incurred at the time that a trade or profession has been set up and commenced shall not be so treated for the purposes of section 381, 396(2) or 420. |