Section 110 amendment to combat aggressive tax practices
The Minister for Finance recently published a proposed amendment to section 110 TCA 1997 which deals with the taxation of special purpose companies set up to securities assets. The amendment is to be introduced following reports that the beneficial tax treatment afforded by section 110 companies is being used for what the Minister called “aggressive tax practices” relating to Irish property transactions.
The proposed amendment will be included in Finance Bill 2016 and once enacted this provision will come into effect from 6th September 2016.
The issue of the use of charitable trusts by section 110 companies is subject to a separate review in accordance with the press statement released with details of the amendments to section 110.