Revenue Note for Guidance
Income tax is charged under Schedule F on dividends paid and other distributions made by Irish resident companies.
(1) par 1 For the purposes of the charge to income tax under Schedule F, “distribution” has the meaning assigned to it by Chapter 2 of Part 6 together with the extension of that meaning provided for by sections 436, 436A, 437, 816(2)(b) and 817. This is the same meaning as “distribution” has for the purposes of the Corporation Tax Acts (see section 4(1)). It should be noted, therefore, that this definition applies for all the purposes of the Corporation Tax Acts but for the purposes of the Income Tax Acts applies only for the purposes of charging to income tax under Schedule F distributions made by a resident company.
(1) par 2 Income tax is chargeable under Schedule F for any year of assessment on dividends/distributions made in that year by an Irish resident company (apart from dividends/distributions which are exempt from a charge to income tax). For income tax purposes, all such distributions are to be treated as income, regardless of the manner in which they are to be dealt with in the hands of the recipient.
(2) A double charge to income tax under Schedule F and some other provision of the Income Tax Acts is prevented by providing that a distribution chargeable to tax under Schedule F is not chargeable under any other provision of the Income Tax Acts.
Relevant Date: Finance Act 2019