Revenue Precedents

An approved institution within the meaning of section 843 [capital allowances for certain third level educational institutions] uses a subsidiary company to manage all its properties. It lets a premises to a subsidiary. A qualifying premises for the purpose of section 843 Taxes Consolidation Act 1997 means, inter alia, one which is let to an approved institution. A wholly owned subsidiary of an approved institution may be regarded as such an institution. Accordingly, if a company is a wholly owned subsidiary of the approved institution the premises may be let to the company and as long as it is used by the approved institution for the purposes of third level education it will be a qualifying premises. 00GM133