Dual Hemisphere or Shuttle Stallions

Issue 33 of Tax Briefing issued in September 1998 outlined the position regarding the taxation of profits arising from the service of mares by, so called, dual hemisphere or shuttle stallions. These are stallions that normally stand in Ireland but are sent abroad to the Southern Hemisphere when the breeding season has finished in Ireland.

In the past, Revenue had accepted that the nomination income from a stallion that is ordinarily kept on land in the State and is temporarily exported for genuine commercial reasons and for a period which will not exceed 2 years will be regarded as exempt from tax in the State [Tax Instruction 7.3.5]. It is accepted that dual hemisphere or shuttle stallions come within this description. This practice was changed with the publication of the article in Tax Briefing in September 1998.

With effect from 1 October 1998, only profits derived from the service of mares within the State by dual hemisphere or shuttle stallions are regarded as exempt from tax in accordance with Section 231 TCA 1997. The profits arising from the servicing of mares outside the State by these stallions are not regarded as exempt from tax under Section 231 TCA 1997. Such profits should be included in the return of income of the person entitled to them.