Revenue Precedents

Treatment of interest in accordance with section 133 of the Taxes Consolidation Act, 1997 (was s.84(2)(d)(iv) Corporation Tax Act, 1976) and the Ireland/Netherlands Double Taxation Convention. Interest paid to a Dutch parent company by its Irish subsidiary will be regarded as interest and will be allowed as trading expense to the paying company. DTX 7008/94

Conflict in the treatment of interest which is treated as a distribution within the meaning of section 133 Taxes Consolidation Act, 1997 (s.84(2)(d)(iv), Corporation Tax Act, 1976) and interest which is treated as such for the purposes of a Double Taxation Convention. Where a conflict arises the Double Taxation Convention provisions will apply unless a claim to the contrary is made by the company. IR 10407/339/95