835S Creditable Tax

Summary

This section provides for a credit to be allowed against the corporation tax arising in respect of a CFC charge for any double tax arising on the chargeable income.

Details

‘(1) “relevant tax’” means tax paid by the CFC arising in its jurisdiction of residence or any other jurisdiction, except the State, which corresponds to corporation tax.

‘(2) “creditable tax’” in respect of an accounting period is the total of:

• the amount of foreign tax paid or borne by the CFC, which can include Irish tax, arising on the CFC’’s chargeable income, and
• any amount of relevant tax paid in the nature of a CFC charge (except for a CFC charge arising in the State) on the CFC’s chargeable income.

(3) Any amount that falls to be repaid to the CFC or any other person shall be excluded.

(4) The credit allowed is ringfenced and limited to the amount of the CFC charge.

Relevant Date: Finance Act 2019