Select view:

Taxes Consolidation Act, 1997 (Number 39 of 1997)

Chapter 2

Income tax and corporation tax: reliefs applicable to both

481 Relief for investment in films.

[FA87 s35(1) to (20); FA96 s31(1); FA97 s30]

(1) In this section—

[89]>

allowable investor company”, in relation to a qualifying company, means a company which is not connected with the qualifying company;

<[89]

[146]>

authorised officer” means an officer of the Revenue Commissioners authorised by them in writing for the purposes of this section;

<[146]

[141]>

[97]>

broadcast” and “broadcaster” have the meanings assigned to them by section 2 of the Broadcasting Act 2009;

<[97]

<[141]

[145]>

assisted region” means an area specified in paragraph (1) of the Annex to the Commission Decision C(2014) 3153;

<[145]

[141]>

broadcast” has the meaning assigned to it by section 2 of the Broadcasting Act 2009;

broadcaster” means a person who has responsibility for a ‘broadcasting service’ as defined in section 2 of the Broadcasting Act 2009;

<[141]

[145]>

certificate” means a certificate issued by the Minister under subsection (2);

<[145]

[77]>

director” shall be construed in accordance with section 433(4);

<[77]

[145]>

eligible expenditure” means the portion of the total cost of production of a qualifying film that is expended on the production of the film in the State—

(a) directly by the qualifying company concerned on the employment of eligible individuals, in so far as those individuals exercise their employment in the production of the film, and

(b) directly or indirectly by the qualifying company concerned, on the provision of certain goods, services and facilities,

as set out in regulations made under subsection (2E);

<[145]

[132]>

[33]>

eligible individual” means an individual who is a citizen of Ireland or of another Member State of the European Communities, or an individual domiciled, resident or ordinarily resident in the State or in another Member State of the European Communities;

<[33]

<[132]

[132]>

eligible individual” means an individual employed by a qualifying company for the purposes of the production of a qualifying film;

<[132]

[90]>

film” means—

[34]>

(a) as respects a film in respect of which the Minister did not receive before the 29th day of April, 1997, the application to enable the Minister to consider whether a certificate should be given under subsection (2)(a), a film of a kind which is included within the categories of films eligible for certification as set out in guidelines referred to in [1]>subsection (2), or<[1][1]>subsection (2), and<[1]

<[34]

[34]>

(a) a film of a kind which is included within the categories of films eligible for certification by the Revenue Commissioners under subsection (2A), as specified in regulations made under subsection (2E), and

<[34]

(b) [2]>as respects any other film<[2][2]>as respects every film<[2], a film which is produced—

(i) on a commercial basis with a view to the realisation of profit, and

(ii) wholly or principally for exhibition to the public in cinemas or by means of television broadcasting,

but does not include a film made for exhibition as an advertising programme or as a commercial;

<[90]

[90]>

film” means—

(a) a film of a kind which is included within the categories of films eligible for certification by the [147]>Revenue Commissioners under subsection (2A), as specified in regulations made under subsection (2E)<[147][147]>Minister under subsection (2)<[147], and

(b) as respects every film, a film which is produced—

(i) on a commercial basis with a view to the realisation of profit, and

(ii) wholly or mainly for exhibition to the public in cinemas or by means of broadcast,

but does not include a film made for exhibition as an advertising programme or as a commercial;

<[90]

[97]>

film corporation tax credit”, in relation to a [148]>qualifying film, means<[148][148]>qualifying film, subject to subsection (1B), means<[148] an amount equal to 32 per cent of the lowest of—

(a) the eligible expenditure amount,

(b) 80 per cent of the total cost of production of the film, and

(c) [142]>€50,000,000<[142][142]>€70,000,000<[142];

producer company”, [149]>in relation to a film corporation tax credit specified in a film certificate,<[149] means a company that—

(a) is resident in the State, or is resident in an EEA State other than the State and carries on business in the State through a branch or agency,

(b) [150]>commencing not later than the time the qualifying period commences,<[150] carries on a trade of producing films—

(i) on a commercial basis with a view to the realisation of profit, and

(ii) that are wholly or principally for exhibition to the public in cinemas or by means of broadcast,

(c) is not a company, or a company connected to a company—

(i) that is a broadcaster, or

(ii) in the case of—

(I) a company, whose business consists wholly or mainly, or

(II) a company connected to another company, where the aggregate of the activities carried on by the company and every company to which it is connected, consists wholly or mainly, of transmitting films on the internet,

(d) holds all of the shares in the qualifying company, [151]>and<[151]

(e) has delivered to the Collector-General[152]>, on or before the specified return date,<[152] a return, in accordance with section 959I, in respect of—

(i) the accounting period referred to in paragraph (a) of the definition of “qualifying period”, or

(ii) each accounting period ending in the qualifying period, referred to in paragraph (b) of that definition,

[153]>as the case may be;<[153][153]>as the case may be, and<[153]

[154]>

(f) is not part of an undertaking which would be regarded as an undertaking in difficulty;

<[154]

[145]>

Rescuing & Restructuring Guidelines” means the Communication of the Commission on Guidelines on State aid for rescuing and restructuring non-financial undertakings in difficulty1;

<[145]

specified amount” has the meaning given to it by subsection (3)(b);

specified relevant person” means a person who is a director or secretary of the producer company at any time during the period commencing when the qualifying period commences and ending 12 months after the [158]>date the compliance report referred to in subparagraph (iii) of subsection (2C)(d)(iii) is provided to the Revenue Commissioners;<[158][158]>date referred to in subsection (2C)(d).<[158]

<[97]

[91]>

the Minister” means the Minister for [35]>Arts, Heritage, Gaeltacht and the Islands<[35][74]>[35]>Arts, Sport and Tourism<[35]<[74][74]>Tourism, Culture and Sport<[74];

<[91]

[91]>

the Minister” means the Minister for Arts, Heritage and the Gaeltacht;

<[91]

[145]>

total cost of production”, in relation to a qualifying company, means the qualifying expenditure, as determined in accordance with regulations made under subsection (2E), that was wholly, exclusively and necessarily incurred to produce the film;

undertaking” means the relevant economic unit that would be regarded as an undertaking for the purposes of the Rescuing & Restructuring Guidelines;

undertaking in difficulty” has the meaning assigned to it by the Rescuing & Restructuring Guidelines.

<[145]

[9]>

qualifying company” means a company which—

(a) is incorporated in the State,

(b) is resident in the State and not resident elsewhere,

(c) exists solely for the purposes of the production and distribution of only one qualifying film, and

(d) does not contain in its name registered under either or both the Companies Acts, 1963 to 1990, or the Registration of Business Names Act, 1963, the words “Ireland”, “Irish”, “Éireann”, “Éire” or “national”,

but paragraph (d) shall apply only as respects a film (being the film the company exists for the production and distribution of) in respect of which the Minister did not receive before the 29th day of April, 1997, the application to enable the Minister to consider whether a certificate should be given under subsection (2)(a);

<[9]

[9]>

qualifying company” means a company which—

(a) (i) is incorporated and resident in the State, or

(ii) is carrying on a trade in the State through a branch or agency,

(b) exists solely for the purposes of the production [133]>and distribution<[133] of only one qualifying film, and

(c) does not contain in its name—

(i) registered under either or both the [144]>Companies Acts, 1963 to 1999<[144][144]>Companies Act 2014<[144], and the Registration of Business Names Act, 1963, or

(ii) registered under the law of the territory in which it is incorporated,

the words “Ireland”, “Irish”, “Éireann”, “Éire” or “National”;

<[9]

[36]>

qualifying film” means a film in respect of which the Minister has given a certificate under subsection (2) which has not been revoked under that subsection;

<[36]

[36]>

qualifying film” means a film in respect of which the [155]>Revenue Commissioners have issued a certificate under subsection (2A), which has not been revoked under subsection (2D)<[155][155]>Minister has issued a certificate under subsection (2)<[155];

<[36]

[92]>

qualifying individual”, in relation to a qualifying company, means an individual who is not connected with the company;

<[92]

[10]>

qualifying period”—

(a) in relation to an allowable investor company, means the period commencing on the 23rd day of January, 1996, and ending on the [3]>22nd day of January, 1999<[3][3]>5th day of April, 2000<[3], and

(b) in relation to a qualifying individual, means the period commencing on the 23rd day of January, 1996, and ending on the [4]>5th day of April, 1999<[4][4]>5th day of April, 2000<[4];

<[10]

[93]>

[10]>

qualifying period”, in relation to an allowable investor company and a qualifying individual, means the period commencing on 23 January 1996, and ending on [28]>5 April 2005<[28][37]>[28]>31 December 2004<[28]<[37][62]>[37]>31 December 2008<[37]<[62][71]>[62]>31 December 2012<[62]<[71][71]>31 December 2015<[71];

<[10]

<[93]

[93]>

qualifying period”, in relation to a film corporation tax credit [156]>specified in a film certificate, <[156]means—

(a) the accounting period of the producer company, in respect of which the specified return date for the chargeable period, within the meaning of section 959A, immediately precedes the date [157]>the application referred to in subsection (2A)(a) was made<[157][157]>the claim referred to in subsection (2G) was made<[157], or

(b) where the accounting period referred to in paragraph (a) is a period of less than 12 months, the period—

(i) commencing on the date on which the most recently commenced accounting period, which commences on or before the date which is 12 months before the end of the accounting period referred to in paragraph (a) commences, and

(ii) ending on the date the accounting period referred to in paragraph (a) ends,

and references in subsection (3) to corporation tax and corporation tax paid shall be construed accordingly;

<[93]

[159]>

(1A) (a) Subject to the provisions of this section, a producer company, that is not an undertaking in difficulty, may make an application to the Minister, in relation to a film to be produced by the company, for the issue by the Minister of a certificate stating that the film is to be treated as a qualifying film for the purpose of this section.

(b) An application for a certificate under paragraph (a) shall be in the form approved by the Minister and shall contain such information as may be specified in regulations made under subsection (2E).

(1B) (a) (i) Where the production of a qualifying film will take place in an assisted region, the producer company, in making its application under subsection (1A) on or after 1 January 2019, may apply for the certificate mentioned in that subsection to specify, in addition to that mentioned in that subsection, that an increased film corporation tax credit (in this section referred to as ‘the regional film development uplift’) shall apply as provided for in paragraph (b).

(ii) In considering whether, in the certification applied for, he or she should specify that the regional film development uplift shall apply, the Minister, in accordance with regulations made under subsection (2E), shall have regard to the following criteria:

(I) whether the production of the film will substantially be undertaken in an assisted region;

(II) whether there is limited availability of individuals with suitable experience or training who habitually reside within a 45 kilometre radius of the place of production to provide services, amounts expended upon which would form part of the eligible expenditure on the qualifying film; and

(III) in respect of the areas of expertise where there is limited availability, whether the company will provide training for individuals that habitually reside within that 45 kilometre radius.

(b) Where the certificate issued specifies that the regional film development uplift is to apply, the percentage specified in the definition of ‘film corporation tax credit’ shall be—

(i) as respects claims made on or before 31 December 2020, 37 per cent,

(ii) as respects claims made after 31 December 2020 but on or before 31 December 2021, 35 per cent,

(iii) as respects claims made after 31 December 2021 but on or before 31 December 2022, 34 per cent, or

(iv) as respects claims made after 31 December 2022, 32 per cent,

and, for the purposes of this paragraph, a reference to a claim is a reference to the first claim that a producer company makes in respect of a qualifying film under subsection (2G).

<[159]

[94]>

relevant deduction” means a deduction of an amount equal to [66]>80 per cent<[66][66]>100 per cent<[66] of a relevant investment;

<[94]

[95]>

relevant investment” means a sum of money which is—

(a) paid in the qualifying period to a qualifying company in respect of shares in the company by an allowable investor company on its own behalf or by a qualifying individual on that individual’s own behalf, and is paid by the allowable investor company or by the qualifying individual, as the case may be, directly to the qualifying company,

[38]>

(b) paid by the allowable investor company or the qualifying individual, as the case may be, for the purposes of enabling the qualifying company to produce a film in respect of which, at the time such sum of money is paid, the Minister has given notice in writing to the qualifying company that the Minister is satisfied for the time being that an application in writing containing such information as may be specified in guidelines referred to in subsection (2) has been made to enable the Minister to consider whether a certificate should be given to that company under that subsection, and

<[38]

[38]>

(b) paid by the allowable investor company or the qualifying individual, as the case may be, for the purposes of enabling the qualifying company to produce a film in respect of which, at the time such sum of money is paid, the authorised officer has given notice in writing to the qualifying company that the Revenue Commissioners are satisfied for the time being that an application in writing, in the form prescribed by the Revenue Commissioners and containing such information as may be specified in regulations made under subsection (2E), has been made to enable the Revenue Commissioners to consider whether a certificate should be issued to that company under subsection (2A), and

<[38]

(c) used by the qualifying company within 2 years of the receipt of that sum for those purposes,

but does not include a sum of money paid to the qualifying company on terms which provide that it will be repaid, [39]>other than a provision for its repayment in the event of the Minister not giving a certificate under subsection (2)<[39][39]>other than a provision for its repayment in the event of the Revenue Commissioners not giving a certificate under subsection (2A)<[39], and a reference to the making of a relevant investment shall be construed as a reference to the payment of such a sum to a [78]>qualifying company.<[78][78]>qualifying company,<[78]

<[95]

[96]>

[79]>

specified relevant person” means any director or secretary of the qualifying company.

<[79]

<[96]

(2) [40]>(a) (i) Subject to subparagraph (ii), the Minister, on the making of an application by a qualifying company, may, in accordance with guidelines laid down by the Minister with the consent of the Minister for Finance, give a certificate to a qualifying company stating, in relation to a film to be produced by the company, that the film may be treated as a qualifying film for the purposes of this section.<[40]

[40]>

(ii) In relation to a film in respect of which the Minister did not receive before the 29th day of April, 1997, the application to enable the Minister to consider whether a certificate should be given under this paragraph, nothing in this section shall be construed as obliging the Minister to give a certificate under this paragraph, and in any case where, in relation to a film, the principal photography has commenced, the first animation drawings have commenced or the first model movement has commenced, as the case may be, before application is made by a qualifying company, the Minister shall not give a certificate under this paragraph.

(iii) An application under this section shall be in such form as the Minister may direct and shall contain such information as may be specified in the guidelines referred to in subparagraph (i).

(b) A certificate given by the Minister under paragraph (a) shall be subject to such conditions as the Minister may consider proper (having regard, in particular, to any contribution which the production of the film is expected to make to either or both the development of the film industry in the State and the promotion and expression of Irish culture) and specifies in the certificate, including—

(i) a condition that not less than—

(I) 75 per cent, or

(II) such lower percentage, not being less than 10 per cent, which in accordance with guidelines laid down under paragraph (a) the Minister specifies in the certificate,

of the work on the production of the film is carried out in the State,

(ii) subject to paragraph (c), a condition that the amount per cent of the total cost of production of the film which may be met by relevant investments shall not exceed the amount per cent (in paragraph (c) referred to as “the specified percentage”) specified in the certificate, and

(iii) a condition that the qualifying company shall, in respect of the qualifying film concerned, notify the Minister in writing of when the principal photography has commenced, the first animation drawings have commenced or the first model movement has commenced, as appropriate.

<[40]

[40]>

[160]>

(a) The Minister, on request from the Revenue Commissioners following an application to them by a [98]>qualifying company<[98][98]>producer company<[98] for a certificate under subsection (2A) in relation to a film to be produced by the company, may subject to paragraph (b) and in accordance with regulations made under subsection (2E), give authorisation to the Revenue Commissioners that they may, subject to subsection (2A), issue a certificate under that subsection to the [98]>qualifying company<[98][98]>producer company<[98] in relation to that film.

<[160]

[160]>

(a) The Minister may, following an application by a producer company under subsection (1A), subject to paragraph (b) and in accordance with regulations made under subsection (2E), issue a certificate to the producer company—

(i) stating that the film is to be treated as a qualifying film for the purpose of this section, and

(ii) specifying whether or not the regional film development uplift applies, if appropriate.

<[160]

(b) In considering whether to [161]>give the authorisation<[161][161]>issue the certificate<[161] referred to in paragraph (a), the Minister, in accordance with regulations made under subsection (2E), shall have regard to—

[162]>

(i) the categories of films eligible for certification by the Revenue Commissioners under subsection (2A), as specified in those regulations, and

<[162]

[162]>

(i) the categories of films eligible for certification under this section, as specified in those regulations,

<[162]

(ii) any contribution which the production of the film is expected to make to either or both the development of the film industry in the State and the promotion and expression of Irish culture,

and where [164]>such authorisation is given<[164][164]>a certificate is issued<[164], the Minister, having regard to those matters, shall specify in [165]>the authorisation such conditions<[165][165]>the certificate such conditions<[165], as the Minister may consider proper, including a condition—

[163]>

(iii) the timing of the application by reference to the commencement of production in the State, and

(iv) the criteria specified in subsection (1B)(a)(ii) if appropriate,

<[163]

[49]>

(I) that not less than—

(A) 75 per cent, or

(B) in the case of a co-production (as specified in regulations made under subsection (2E)), such lower percentage, not being less than 10 per cent, which, the Minister specifies in the authorisation,

of the work on the production of the film shall be carried out in the State,

<[49]

(II) in relation to—

(A) the employment and responsibilities of the producer, and the producer company, of a film for the production of that film, and

(B) the employment of personnel, including trainees, (other than the producer) for the [166]>production of that film.<[166][166]>production of that film,<[166]

<[40]

[167]>

(III) the nature and detail of acknowledgement in the opening titles or closing credits of the film, and

(IV) in respect of the Communication from the Commission (2013/C 332/01)2

(A) the maximum aid intensity, and

(B) whether the film may be regarded as a difficult audiovisual work.

(c) Nothing in this section shall be construed as obliging the Minister to issue a certificate.

(d) The Minister may amend or revoke any condition (including a condition added by virtue of this paragraph) specified in the certificate, or add to such conditions, by giving notice in writing to the producer company concerned of the amendment, revocation or addition, and this section shall apply as if—

(i) a condition so amended or added by the notice was specified in the certificate, and

(ii) a condition so revoked was not specified in the certificate.

<[167]

[11]>

(c) (i) Subject to subparagraphs (ii) and (iii), the specified percentage shall not exceed—

(I) where the total cost of production of the film does not exceed £4,000,000, 60 per cent,

(II) where the total cost of production of the film exceeds £4,000,000 and does not exceed £5,000,000, the amount per cent (in this subparagraph referred to as “the allowable percentage”) where the amount of the allowable percentage is determined by the formula—

E

60 –

£100,000

where E is the excess of the total cost of production of the film over £4,000,000, and

(III) where the total cost of production of the film exceeds £5,000,000, 50 per cent;

but, in any case to which clause (I), (II) or (III) relates, the total cost of production of the film which is met by relevant investments shall not exceed £7,500,000, and where the percentage of the work on the production of the film carried out in the State (in this paragraph referred to as the “lower percentage”) is less than 50 per cent, this paragraph shall be construed as if the reference to 60 per cent, the reference to the allowable percentage and the reference to 50 per cent were a reference to the lower percentage.

(ii) (I) In relation to a film (other than an animation film) in respect of which the principal photography commences at any time during the months of October, November, December and January, and the production of the film continues to completion without unreasonable delay from that time, or

(II) in relation to a film in respect of which post production work is to be carried out wholly or mainly in the State,

the references in subparagraph (i) to—

(A) 60 per cent shall be construed as a reference to 66 per cent,

(B) 50 per cent shall be construed as a reference to 55 per cent, and

(C) £7,500,000 shall be construed as a reference to £8,250,000.

(iii) In relation to a film in respect of which not less than one-half of the amount of the total cost of production met by relevant investments has been met by relevant investments paid by allowable investor companies, the references in this paragraph (apart from this subparagraph) to—

(I) £7,500,000 shall be treated as a reference to £15,000,000 and

(II) £8,250,000 shall be treated as a reference to £16,500,000.

<[11]

[59]>

[11]>

(c) The specified percentage shall not exceed—

(i) where the total cost of production of the film does not exceed £4,000,000, 66 per cent,

(ii) where the total cost of production of the film exceeds [12]>£4,000,000<[12][12]>€5,080,000<[12] and does not exceed [14]>£5,000,000<[14][14]>€6,350,000<[14], the amount per cent (in this subparagraph referred to as the “allowable percentage”) where the amount of the allowable percentage is determined by the formula—

[29]>

(11 × E)

66 –

[15]>£1,000,000<[15][15]>€127,000<[15]

<[29]

[29]>

(11 × E)

66 –

€1,270,000

<[29]

where E is the excess of the total cost of production of the film over [13]>£4,000,000<[13][13]>€5,080,000<[13], and

(iii) where the total cost of production of the film exceeds [16]>£5,000,000<[16][16]>€6,350,000<[16], 55 per cent;

but, in any case to which subparagraph (i), (ii) or (iii) relates, the total cost of production of the film which is met by relevant investments shall not exceed [17]>£8,250,000<[17][41]>[17]>€10,480,000<[17]<[41][41]>€15,000,000<[41].

<[11]

<[59]

[99]>

[59]>

(c) The specified percentage shall not exceed 80 per cent but, in any case to which this paragraph relates, the total cost of production of the film which is met by relevant investments shall not exceed [63]>€35,000,000<[63][63]>€50,000,000<[63].

<[59]

<[99]

[42]>

(d) The Minister may amend or revoke any condition (including a condition added by virtue of this paragraph) specified in the certificate, or add to such conditions, by giving notice in writing to the qualifying company concerned of the amendment, revocation or addition, and this section shall apply as if—

(i) a condition so amended or added by the notice was specified in the certificate, and

(ii) a condition so revoked was not specified in the certificate.

(e) Where a company fails to comply with any of the conditions to which a certificate issued to it under paragraph (a) is subject by virtue of paragraph (b) or (d)

(i) that failure shall constitute the failure of an event to happen by reason of which relief is to be withdrawn under subsection (11), and

(ii) the Minister may, by notice in writing served by registered post on the company, revoke the certificate.

<[42]

[43]>

(2A)

[168]>

(a) Subject to the provisions of this subsection, the Revenue Commissioners, on the making of an application by a [100]>qualifying company<[100][100]>producer company<[100], may, in accordance with regulations made under subsection (2E), issue a certificate to a [100]>qualifying company<[100][100]>producer company<[100] stating, in relation to a film to be produced by the company, that the film may be treated as a qualifying film for the purpose of this section.

<[168]

[101]>

(b) The Revenue Commissioners shall not issue a certificate under paragraph (a) unless given authorisation that they may do so by the Minister under subsection (2)(a).

<[101]

[101]>

[169]>

(b) The Revenue Commissioners shall not issue a certificate under paragraph (a) if—

(i) they have not been given authorisation to do so by the Minister under subsection (2)(a),

<[169]

[169]>

A producer company shall not make a claim for the film corporation tax credit under subsection (2G) if—

(i) there has not been issued to the producer company a certificate by the Minister in respect of that film,

<[169]

(ii) the producer company, the qualifying company[134]>, any company controlled by the producer company<[134] and each person who is either the beneficial owner of, or able directly or indirectly to control, more than 15 per cent of the ordinary share capital of the producer company or the qualifying company, as the case may be, is not in compliance with all the obligations imposed by the Tax Acts, the Capital Gains Tax Acts or the Value-Added Tax Consolidation Act 2010 in relation to—

(I) the payments or remittances of taxes, interest or penalties required to be paid or remitted under those Acts,

(II) the delivery of returns, and

(III) requests to supply to an inspector accounts of, or other information about, any business carried on, by the producer company, the qualifying company or person, as the case may be,

<[101]

[135]>

or

<[135]

(iii) the eligible expenditure amount is less than [136]>€200,000.<[136][170]>[136]>€125,000, or<[136]<[170][170]>€125,000,<[170]

<[43]

[137]>

(iv) the total cost of the production of the film is less than [171]>€250,000.<[171][171]>€250,000,<[171]

<[137]

[172]>

(v) it is an undertaking in difficulty,

(vi) any company in an undertaking of which the producer company is part is subject to an outstanding recovery order following a previous decision of the Commission that declared an aid illegal and incompatible with the internal market, or

(vii) in relation to a claim under subsection (2G)(b)(i)—

(I) the agreements pursuant to which the financing of the film will be made available have not been executed, or the conditions that are required to be satisfied in those agreements for funding to commence have not been fulfilled, and

(II) an amount not less than 68 per cent of the amount on which the film corporation tax credit is based has not been lodged to an account held by the qualifying company with a financial institution on terms whereby such amount is to be expended by the qualifying company on the production of the film,

but neither clause (I) nor (II) shall apply where such other confirmations of financing, as set out in regulations under subsection (2E) and specified by those regulations to be acceptable for this purpose, are available.

<[172]

[138]>

(c) Nothing in this section shall be construed as obliging the Revenue Commissioners to issue a certificate under paragraph (a) and in any case where, in relation to a film, the principal photography has commenced, the first animation drawings have commenced or the first model movement has commenced, as the case may be, before application is made by a [102]>qualifying company<[102][102]>producer company<[102], the Revenue Commissioners shall not issue a certificate under that paragraph.

<[138]

[173]>

[138]>

(c) Nothing in this section shall be construed as obliging the Revenue Commissioners to issue a certificate under paragraph (a).

<[138]

<[173]

[174]>

(d) An application for a certificate under paragraph (a) shall be in the form prescribed by the Revenue Commissioners and shall contain such information as may be specified in regulations made under subsection (2E).

<[174]

[175]>

(e) In considering whether to issue a certificate under paragraph (a) the Revenue Commissioners shall, in respect of the proposed production of the film, examine all aspects of the [103]>qualifying company<[103][103]>producer company<[103]’s proposal.

<[175]

[176]>

(f) The Revenue Commissioners may refuse to issue a certificate under paragraph (a) if they are not satisfied with any aspect of the [104]>qualifying company<[104][104]>producer company<[104]’s application and, in particular, the Revenue Commissioners may refuse to issue a certificate—

(i) if they have reason to believe that the budget or any particular item of proposed expenditure in the budget is inflated, or

(ii) where—

(I) they are not satisfied that there is a commercial rationale for the corporate structure proposed—

(A) for the production, financing, distribution or sale of the film, or

(B) for all of those purposes,

or

(II) they are of the opinion that the corporate structure proposed would hinder the Revenue Commissioners in verifying compliance with any of the provisions governing the relief.

<[176]

[176]>

(f) A producer company shall not make a claim under subsection (2G) if it would be reasonable to consider that—

(i) in respect of a claim under subsection (2G)(b)(i), the budget or any particular item of proposed expenditure in the budget is inflated, or

(ii) (I) there is no commercial rationale for the corporate structure—

(A) for the production, financing, distribution or sale of the film, or

(B) for all of those purposes,

or

(II) the corporate structure would hinder the Revenue Commissioners in verifying compliance with any of the provisions governing the relief.

<[176]

[177]>

(g) A certificate issued by the Revenue Commissioners under paragraph (a) shall be subject to such conditions specified in the certificate as the Revenue Commissioners may consider proper, having regard, in particular, to the examination referred to in paragraph (e) and any conditions specified in the authorisation given by the Minister under subsection (2)(a), and in particular the Revenue Commissioners shall specify in the certificate a condition—

[50]>

(i) in relation to the percentage of the work on the production of the film which shall be carried out in the State, as specified by the Minister in the authorisation,

<[50]

[105]>

(i) in relation to the quantum of the specified amount, and the timing and manner of a payment of the specified amount,

<[105]

(ii) in relation to the matters specified by the Minister in the authorisation by virtue of subsection (2)(b)(II),

[106]>

(iii) subject to subsection (2)(c), that the amount per cent of the total cost of production of the film which may be met by relevant investments shall not exceed [51]>the specified percentage, as referred to in that subsection<[51][51]>the amount per cent (in subsection (2)(c) referred to as “the specified percentage”) specified in the certificate<[51],

<[106]

[106]>

(iii) in relation to the amount of the film corporation tax credit by which the producer company’s corporation tax is to be reduced,

<[106]

[52]>

(iv) in relation to the minimum amount of money to be expended directly—

(I) on the employment of eligible individuals, and

(II) on the provision of certain goods, services and facilities, as set out in regulations made under subsection (2E),

on the production of the qualifying film.

<[52]

[52]>

(iv) in relation to the minimum amount of money to be expended on the production of the qualifying film [107]>(in this section referred to as the eligible expenditure amount)<[107]

(I) directly by the qualifying company on the employment, by the company, of eligible individuals, in so far as those individuals exercise their employment in the State in the production of the qualifying film, and

(II) directly or indirectly by the qualifying company, on the provision of certain goods, services and facilities, as set out in regulations made under subsection (2E),

<[52]

[53]>

(v) where financial arrangements have been approved by the Revenue Commissioners in accordance with [80]>subsection (2C)(ba)<[80][80]>subsection (2CA)<[80], in relation to any matter pertaining to those arrangements.

<[53]

<[177]

[178]>

(h) The Revenue Commissioners, having consulted with the Minister as appropriate, may amend or revoke any condition (including a condition added by virtue of this paragraph) specified in the certificate, or add to such conditions, by giving notice in writing to the [108]>qualifying company<[108][108]>producer company<[108] concerned of the amendment, revocation or addition, and this section shall apply as if—

(i) a condition so amended or added by the notice was specified in the certificate, and

(ii) a condition so revoked was not specified in the certificate.

<[178]

[179]>

(i) Before making a claim a producer company shall have such information and records as the Revenue Commissioners may reasonably require for the purposes of determining whether that claim complies with this section.

<[179]

(2B) In carrying out their functions under this section the Revenue Commissioners may—

(a) consult with any person, agency or body of persons, as in their opinion may be of assistance to [180]>them, and<[180][180]>them,<[180]

(b) notwithstanding any obligation as to secrecy or other restriction on the disclosure of information imposed by, or under, the Tax Acts or any other statute or otherwise, disclose any detail in a [109]>qualifying company<[109][109]>producer company<[109]’s application which they consider necessary for the purposes of such [181]>consultation.<[181][181]>consultation, and<[181]

[182]>

(c) where they have reason to believe that financial arrangements have been entered into in contravention of subsection (2C)(b), the Revenue Commissioners may seek any information they consider appropriate in relation to the arrangements or in relation to any person who is, directly or indirectly, a party to the arrangements.

<[182]

(2C) A company shall not be regarded as a [110]>qualifying company<[110][183]>[110]>producer company<[110] for the purposes of this section<[183][183]>producer company in respect of a qualifying film for the purposes of this section<[183]

[139]>

(a) unless the company, in relation to a qualifying film, notifies the Revenue Commissioners in writing immediately when the principal photography has commenced, the first animation drawings have commenced or the first model movement has commenced, as appropriate,

<[139]

[184]>

[139]>

(a) unless the company, in relation to a qualifying film, following the date on which an application has been made under subsection (2A) (d), notifies the Revenue Commissioners in writing within 7 days of the first incurring of expenditure to which subsection (2A)(g)(iv) refers.

<[139]

<[184]

(b) [81]>[54]>subject to paragraph (ba),<[54]<[81][185]>[81]>subject to subsection (2CA),<[81]<[185] if the financial arrangements which the company [111]>or the qualifying company<[111] enters into in relation to the qualifying film are—

(i) financial arrangements of any type with a person resident, registered or operating in a territory other than—

(I) a Member State of the European Communities, or

(II) a territory with the government of which, arrangements having the force of law by virtue of [61]>section 826(1)(a)<[61][61]>section 826(1)<[61], have been made,

or

(ii) financial arrangements under which funds are channelled, directly or indirectly, to, or through, a territory other than a territory referred to in clause (I) or (II) of subparagraph (i),

[82]>

[55]>

(ba) (i) Paragraph (b) shall not apply to financial arrangements in relation to a transaction or series of transactions, where such arrangements have been approved by the Revenue Commissioners.

(ii) The Revenue Commissioners shall not approve financial arrangements, to which paragraph (b) would, but for this paragraph, apply unless:

(I) the arrangements relate to either or both—

(A) an investment made in a qualifying film, and

(B) the filming of part of a film in a territory other than a territory referred to in clause (I) or (II) of paragraph (b)(i),

(II) a request for approval is made by the qualifying company to the Revenue Commissioners before such arrangements are effected,

(III) the qualifying company demonstrates to the satisfaction of the Revenue Commissioners that it can provide, if requested, sufficient records to enable the Revenue Commissioners to verify—

(A) in the case of an investment, the amount of the investment made in the qualifying company and the person who made the investment, and

(B) in the case of filming in a territory, the amount of each item of expenditure on the production of the qualifying film expended in the territory, whether expended by the qualifying company or by any other person,

and

(IV) they are satisfied that it is appropriate to grant such approval.

(iii) In considering whether to grant an approval under this paragraph in relation to financial arrangements, the Revenue Commissioners may seek any information they consider appropriate in relation to the arrangements or in relation to any person who is, directly or indirectly, a party to the arrangements.

(iv) Where the Revenue Commissioners have approved financial arrangements in accordance with this paragraph, no amount of money expended, either directly or indirectly, as part of the arrangements may be regarded, for the purposes of subsection (2A)(g)(iv), as an amount of money expended on either the employment of eligible individuals or on the provision of goods, services and facilities as referred to in that subsection.

<[55]

<[82]

[186]>

other than where those arrangements—

(A) relate to the filming of part of the qualifying film in a territory other than a territory referred to in clause (I) or (II) of subparagraph (i),

(B) the producer company has sufficient records to enable the Revenue Commissioners to verify, in the case of filming in such a territory, the amount of each item of expenditure on the production of the qualifying film expended in the territory, whether expended by the producer company or by any other person, and

(C) the producer company has such records in place to substantiate such expenditure in advance of making a claim under subsection (2G).

<[186]

(c) [187]>unless the company provides, when requested to do so by the Revenue Commissioners, for the purposes of verifying compliance with the provisions governing the relief or with any condition specified in a certificate issued by them under subsection (2A)(a),<[187][187]>without prejudice to the generality of section 886, unless the company provides, when requested to do so by the Revenue Commissioners, for the purposes of verifying compliance with the provisions governing the relief or with any condition specified in a certificate issued by the Minister under subsection (2),<[187] evidence to vouch each item of expenditure in the State or elsewhere on the production and distribution of the qualifying film, whether expended by [112]>the producer company,<[112] the qualifying company or by any other person engaged, directly or indirectly, by [113]>the producer company or<[113] the qualifying company to provide goods, services or facilities in relation to such production or distribution and, in particular, such evidence shall include—

(i) records required to be kept or retained by the [114]>company<[114][114]>producer company or the qualifying company<[114] by virtue of section 886, and

(ii) records, in relation to the production and distribution of the qualifying film, required to be kept or retained by that other person by virtue of section 886, or which would be so required if that other person were subject to the provisions of that section,

[188]>

(ca) unless the company provides, when requested to do so by the Revenue Commissioners, for the purposes of verifying compliance with the provisions governing the relief or with any condition specified in a certificate issued by the Minister under subsection (2) a copy of the film in such format and manner required under paragraph (d)(ii).

<[188]

[83]>

and

<[83]

(d) unless the company, within such time as is specified in the regulations made under subsection (2E)

[189]>

(i) notifies the Revenue Commissioners in writing of the date of completion of the production of the qualifying film,

(ii) provides to the Revenue Commissioners and to the Minister, such number of copies of the film in such format and manner as may be specified in those regulations, and

(iii) provides to the Revenue Commissioners, a compliance report, in such format and manner specified in those regulations, which proves to the satisfaction of the Revenue Commissioners that—

(I) the provisions of this section in so far as they apply in relation to the company and a qualifying film have been met, and

(II) any conditions attaching to a certificate issued to the company in relation to a qualifying film under subsection (2A)(a) have been [84]>fulfilled.<[84][84]>fulfilled,<[84]

<[189]

[189]>

(i) notifies the Minister in writing of the date of completion of the production of the qualifying film, and

(ii) provides to the Minister such number of copies of the film in such format and manner as may be specified in those regulations.

<[189]

[190]>

(da) makes a claim under subsection (2G)(b)(ii), within the time referred to in paragraph (d), and has available, prior to making that claim, a compliance report, in such format and manner specified in those regulations, which provides proof that—

(i) the provisions of this section in so far as they apply in relation to the company and a qualifying company have been met, and

(ii) any conditions attaching to the certificate issued to the company in relation to a qualifying film have been fulfilled,

<[190]

[85]>

[115]>

and

<[115]

[116]>

(e) if any sum representing—

(i) a repayment of a relevant investment, or

(ii) an amount in connection with a relevant investment, out of the proceeds of exploiting the film—

is paid to an allowable investor company or qualifying individual, as the case may be, before the Revenue Commissioners have notified the company in writing that a compliance report, as referred to in paragraph (d)(iii), has been received by them.

<[116]

[116]>

(e) if the company ceases to carry on the trade referred to in paragraph (b) of the definition of “producer company”, before a time which is 12 months after the [191]>date the compliance report referred to in subsection (2C)(d)(iii) is provided to the Revenue Commissioners<[191][191]>date referred to in paragraph (d)<[191],

<[116]

<[85]

[117]>

(f) if the company disposes of its shares in the qualifying company before a time which is 12 months after the [192]>date the compliance report referred to in subsection (2C)(d)(iii) is provided to the Revenue Commissioners<[192][192]>date referred to in paragraph (d), and<[192],

(g) unless the company—

(i) enters into a contract with the qualifying company in relation to the production [140]>and distribution<[140] of the qualifying film, and

(ii) provides an amount not less than the specified amount to the [193]>qualifying company, and<[193][193]>qualifying company.<[193]

[194]>

(h) unless an amount not less than the eligible expenditure amount is expended by the qualifying company wholly and exclusively on the production of the qualifying film as specified in a condition in a film certificate, in accordance with subsection (2A)(g)(iv).

<[194]

<[117]

[195]>

[86]>

(2CA) (a) Paragraph (b) of subsection (2C) shall not apply to financial arrangements in relation to a transaction, or series of transactions, where such arrangements have been approved by the Revenue Commissioners.

(b) The Revenue Commissioners shall not approve financial arrangements, to which paragraph (b) of subsection (2C) would, but for this subsection, apply unless:

[118]>

(i) the arrangements relate to either or both—

(I) an investment made in a qualifying film, and

(II) the filming of part of a film in a territory other than a territory referred to in clause (I) or (II) of subsection (2C)(b)(i),

<[118]

[118]>

(i) the arrangements relate to the filming of part of a film in a territory other than a territory referred to in clause (I) or (II) of subsection (2C)(b)(i),

<[118]

(ii) a request for approval is made by [119]>the qualifying company<[119][119]>the producer company<[119] to the Revenue Commissioners before such arrangements are effected,

[120]>

(iii) the qualifying company demonstrates to the satisfaction of the Revenue Commissioners that it can provide, if requested, sufficient records to enable the Revenue Commissioners to verify—

(I) in the case of an investment, the amount of the investment made in the qualifying company and the person who made the investment, and

(II) in the case of filming in a territory, the amount of each item of expenditure on the production of the qualifying film expended in the territory, whether expended by the qualifying company or by any other person,

<[120]

[120]>

(iii) the producer company demonstrates to the satisfaction of the Revenue Commissioners that it can provide, if requested, sufficient records to enable the Revenue Commissioners to verify, in the case of filming in a territory, the amount of each item of expenditure on the production of the qualifying film expended in the territory, whether expended by the producer company or by any other person,

<[120]

and

(iv) they are satisfied that it is appropriate to grant such approval.

(c) In considering whether to grant an approval under this subsection in relation to financial arrangements, the Revenue Commissioners may seek any information they consider appropriate in relation to the arrangements or in relation to any person who is, directly or indirectly, a party to the arrangements.

(d) Where the Revenue Commissioners have approved financial arrangements in accordance with this subsection, no amount of money expended, either directly or indirectly, as part of the arrangements may be regarded, for the purposes of subsection (2A)(g)(iv), as an amount of money expended on either the employment of eligible individuals or on the provision of goods, services and facilities as referred to in that subsection.

<[86]

<[195]

[121]>

(2D) Where a company fails—

(a) to comply with any of the provisions of subsection (2C) or any other provision governing the relief, or

(b) to fulfil any of the conditions to which a certificate issued to it under paragraph (a) of subsection (2A) is subject, by virtue of paragraph (g) or (h) of that subsection,

that failure shall constitute the failure of an event to happen by reason of which relief may be withdrawn under subsection (11) and the Revenue Commissioners may, by notice in writing served by registered post on the company, revoke the certificate.

<[121]

[196]>

[121]>

(2D) Where the producer company or the qualifying company fails to comply with any of the provisions of this section or fails to fulfil any condition specified in a certificate issued to the producer company under paragraph (a) of subsection (2A), the Revenue Commissioners may, by notice in writing, revoke the certificate.

<[121]

<[196]

(2E) The Revenue Commissioners with the consent of the Minister for Finance, and with the consent of the Minister in relation to the matters to be considered regarding [197]>the issue of an authorisation under subsection (2)<[197][197]>the issue of a certificate under subsection (2)<[197], shall make regulations with respect to the administration by them of the relief under this section and with respect to the matters to be considered by the Minister for the purposes of that subsection and, without prejudice to the generality of the foregoing, regulations under this subsection may include provision—

(a) governing the application for certification [198]>pursuant to subsection (2A)<[198][198]>, the timing of such an application<[198] and the information and documents to be provided in or with such application,

(b) specifying the categories of films eligible for certification [199]>by the Revenue Commissioners under subsection (2A)<[199],

[200]>

(c) prescribing the form of such application,

<[200]

(d) governing the records that [122]>a qualifying company<[122][122]>a producer company and a qualifying company<[122] shall maintain or provide to the Revenue Commissioners,

(e) governing the period for which, and the place at which, such records shall be maintained,

(f) specifying the time within which a [123]>qualifying company<[123][123]>producer company<[123] shall notify the [201]>Revenue Commissioners<[201][201]>Minister<[201] of the completion of the production of a qualifying film,

(g) specifying the time within which, and the format, number and manner in which, copies of a qualifying film shall be provided to [202]>the Revenue Commissioners and to<[202] the Minister,

[203]>

(h) specifying the form and content of the compliance report to be provided to the Revenue Commissioners, the manner in which such report shall be made and verified, the documents to accompany the report and the time within which such report shall be provided,

<[203]

[203]>

(h) specifying the form and content of the compliance report that must be available in accordance with subsection (2C)(d)(iii), the manner in which such report shall be made and verified, and the documents to accompany the report,

<[203]

(i) governing the type of expenditure which may be [204]>accepted by the Revenue Commissioners as<[204][204]>treated as qualifying or eligible<[204] expenditure on the production of a qualifying film,

(j) governing the provision of the goods, services and facilities referred to [205]>in subsection (2A)(g)(iv)(II)<[205][205]>in the definition of eligible expenditure<[205], including the place of origin of those goods, services and facilities, the place in which they are provided and the location of the supplier,

(k) specifying the currency exchange rate to be applied to expenditure on the production of a qualifying film, [56]>and<[56]

(l) specifying the criteria to be considered by the Minister, in relation to the matters referred to in [206]>subsections (2)(b)(i) and (ii)<[206][206]>subsection (2)(b)<[206]

(i) in deciding whether to [207]>give authorisation to the Revenue Commissioners<[207][207]>issue a certificate<[207] under subsection (2)(a), and

(ii) in specifying conditions in such [208]>authorisation<[208][208]>certificate<[208], as provided for in subsection (2)(b),

and the information required for those purposes to be included in the application made to the [209]>Revenue Commissioners under subsection (2A)<[209][209]>Minister<[209] by a [124]>qualifying company<[124][124]>producer company<[124].

[210]>

(la) specifying the criteria to be considered by the Minister, in relation to the matters referred to in subsection (1B)(a)(ii)—

(i) in deciding whether, in the certificate applied for under subsection (1A), he or she should specify that the regional film development uplift shall apply, and

(ii) in specifying conditions in such a certificate, as provided for in subsection (2)(b),

and the information required for those purposes to be included in the application made to the Minister by a producer company,

<[210]

[57]>

(m) governing [211]>the approval of<[211] financial arrangements in accordance with [87]>subsection (2C)(ba)<[87][212]>[87]>subsection (2CA)<[87]<[212][212]>subsection (2C)(b)<[212], [125]>and<[125]

[213]>

(ma) specifying the confirmations of financing that are acceptable for the purpose of subsection (2A)(b)(vii),

<[213]

(n) governing the employment of eligible individuals[214]>, as referred to in subsection (2A)(g)(iv),<[214] and the circumstances in which expenditure by a qualifying company would be regarded as expenditure on the employment of those individuals in the production of a qualifying [126]>film.<[126][126]>film, and<[126]

<[57]

[215]>

[127]>

(o) governing when the specified amount may be paid by the Revenue Commissioners to the producer company.

<[127]

<[215]

[215]>

(o) governing the payment of the specified amount by the Revenue Commissioners to the producer company.

<[215]

[216]>

[88]>

(2F) Where a [128]>qualifying company<[128][128]>producer company<[128] fails to provide to the Revenue Commissioners a compliance report as referred to in subsection (2C)(d)(iii), within the time provided for in regulations made under subsection (2E)(h), the specified relevant person shall provide such compliance report to the Revenue Commissioners within 2 months after that time.

<[88]

<[216]

[217]>

(2G) (a) In this section the ‘budgeted film corporation tax credit’ means the amount of the film corporation tax credit that would be payable if the amounts set out in the budget in respect of a qualifying film to be produced were incurred on the production of that qualifying film.

(b) Where the Minister has issued a certificate in relation to a qualifying film to a producer company and the provisions of this section have been complied with, a producer company may make a claim—

(i) in advance of the date referred to in subsection (2C)(d), for an amount not exceeding 90 per cent, or such lower amount as set out in regulations under subsection (2E), of the budgeted film corporation tax credit, or

(ii) in any other case, for the film corporation tax credit, less any amount already claimed pursuant to subparagraph (i).

(c) A claim under paragraph (b) shall be made in the return required under Part 41A, the specified return date of which immediately precedes the making of the claim.

<[217]

[129]>

(3) Subject to this section, where in an accounting period an allowable investor company makes a relevant investment, it shall, on making a claim in that behalf, be given a relevant deduction from its total profits for the accounting period; but, where the amount of the relevant deduction to which the allowable investor company is entitled under this section in an accounting period exceeds its profits for that accounting period, [69]>an amount equal to 125 per cent of the amount<[69][69]>the amount<[69] of that excess shall be carried forward to the succeeding accounting period and the amount so carried forward shall be treated for the purposes of this section as if it were a relevant investment made in that succeeding accounting period.

<[129]

[129]>

(3)

[218]>

(a) Where the Revenue Commissioners have—

(i) issued a film certificate to a producer company, in accordance with subsection (2A)(a), and

(ii) specified an amount of a film corporation tax credit in the certificate,

the corporation tax of the company for the qualifying period, shall, subject to subsection (2A)(g)(iii), be reduced by so much of an amount equal to the film corporation tax credit specified in the film certificate as does not exceed that corporation tax and where the qualifying period is a period referred to in paragraph (b) of the definition of “qualifying period”, the corporation tax of an earlier accounting period shall be reduced in priority to the corporation tax of a later accounting period.

<[218]

[218]>

(a) Where a producer company makes a claim under subsection (2G), the corporation tax of the company, for the qualifying period, shall be reduced by so much of an amount equal to the film corporation tax credit as does not exceed that corporation tax and where the qualifying period is a period referred to in paragraph (b) of the definition of ‘qualifying period’, the corporation tax of an earlier accounting period shall be reduced in priority to the corporation tax of a later accounting period.

<[218]

(b) Subject to subsection (3C), where [219]>the Revenue Commissioners have specified a film corporation tax credit in a film certificate<[219][219]>a producer company has made a claim under subsection (2G)<[219] and the amount of the credit exceeds the corporation tax of the qualifying period, as reduced by the corporation tax paid by the company in respect of that period but before any reduction under paragraph (a), the excess (in this section referred to as the “specified amount”) shall be paid to the producer company by the Revenue Commissioners.

[220]>

(c) The specified amount shall be paid by the Revenue Commissioners to the film producer company not later than the date specified in the film certificate issued to the company, which shall not be earlier than the date set out in the regulations made under subsection (2E).

<[220]

<[129]

[130]>

(3A) (a) Any amount payable by the Revenue Commissioners to the company by virtue of subsection (3)(b) shall be deemed to be an overpayment of corporation tax, for the purposes only of section 960H(2).

(b) Any claim in respect of a specified amount shall be deemed for the purposes of section 1077E to be a claim in connection with a credit and, for the purposes of determining an amount in accordance with section 1077E(11) or 1077E(12), a reference to an amount of tax that would have been payable for the relevant periods by the person concerned shall be read as if it were a reference to a specified amount.

(c) Where the Revenue Commissioners have paid a specified amount to a producer company and it is subsequently found that all or part of the amount is not as authorised by this section (in this section referred to as the “unauthorised amount”), then—

(i) the company,

(ii) any director of the company, or

(iii) any person referred to in subparagraph (ii) of paragraph (b) of subsection (2A),

may be charged to tax under Case IV of Schedule D for the accounting period, or year of assessment, as the case may be, in respect of which the payment was made, in an amount equal to—

(I) in the case of a company, 4 times, and

(II) in the case of an individual, one hundred [143]>forty-firsts<[143] [143]>fortieths<[143],

of so much of the specified amount as is not so authorised.

(d) The circumstances in which an unauthorised amount arises shall include any circumstances where [221]>the amount was paid<[221][221]>the amount was claimed under subsection (2G) or paid<[221] in accordance with paragraph (b) of subsection (3) and—

[222]>

(i) the Revenue Commissioners revoke a certificate issued under subsection (2A)(a), or

<[222]

[222]>

(i) the company made a claim contrary to subsection (2G),

<[222]

(ii) the producer company or the qualifying company—

(I) fails to satisfy or comply with any condition or obligation required by this section or regulations made under this section,

(II) fails to satisfy or comply with any condition or obligation specified in a [223]>film certificate<[223][223]>certificate<[223], including a condition to complete, deliver, exhibit or make available for exhibition the qualifying film by a time specified in a [223]>film certificate<[223][223]>certificate<[223], or

(III) at any time on or before the time referred to in subsection (2C)(e) fails to comply with any of the obligations referred to in [224]>subsection (2A)(b)(ii).<[224][224]>subsection (2A)(b)(ii),<[224]

[225]>

or

(iii) where a claim is made under subsection (2G)(b)(i) and—

(I) there has occurred a reduction in the expenditure, from the amount as stood budgeted, in respect of the qualifying film and the extent of that reduction is such that the amount claimed is in excess of 90 per cent of the revised budgeted film corporation tax credit (that is to say, that tax credit as it stands revised in consequence of that reduction), or

(II) where an amount equal to the budgeted eligible expenditure upon which a claim was based is not expended by the qualifying company wholly and exclusively on the production of the qualifying film without unreasonable delay.

<[225]

(e) Where in accordance with paragraph (c) [226]>an inspector makes an assessment<[226][226]>an assessment is made or amended<[226] in respect of a specified amount, the amount so charged shall for the purposes of section 1080 be deemed to be tax due and payable and shall carry interest as determined in accordance with subsection (2)(c) of section 1080 as if a reference to the date when the tax became due and payable were a reference to the date the amount was paid by the Revenue Commissioners.

(3B) (a) The amount which is provided by the producer company to the qualifying company in accordance with subparagraph (ii) of subsection (2C)(g) shall not—

(i) be a sum which may be deducted in computing the profits or gains to be charged to tax under Case I of Schedule D and shall not otherwise reduce the income of the producer company,

(ii) subject to subsection (3), reduce the corporation tax of the producer company,

(iii) be provided in a manner which is wholly or partly for the purpose of, or in connection with, securing a tax advantage, or

(iv) be income of the qualifying company for any tax purpose.

(b) A failure by the qualifying company to repay any part of the amount referred to in paragraph (a) to the producer company shall not be a sum which may be deducted in computing the profits or gains of the producer company to be charged to tax under Case I of Schedule D and shall not otherwise reduce the income of the producer company.

(c) Notwithstanding sections 411 and 616, the producer and the qualifying company shall be deemed not to be members of the same group of companies for the purposes of—

(i) section 411, or

(ii) except for the purposes of section 626, section 616.

(d) A loss, for the purposes of section 546, shall not be treated as arising on the disposal by the producer company of shares in the qualifying company.

(e) Section 626B shall be deemed not to apply to the disposal by the producer company of shares in the qualifying company.

(f) For the purposes of section 538(2), the value of the shares held by the producer company in the qualifying company, shall not, at any time, be negligible.

(3C) The Revenue Commissioners shall not pay a specified amount to a producer company in respect of [227]>a film certificate issued after 31 December 2020<[227][227]>a certificate issued after 31 December 2024<[227].

<[130]

[131]>

(4) (a) [5]>Subject to paragraph (b), where in any period of 12 months (in paragraph (b) referred to as a “12 month period”) ending on an anniversary of the 22nd day of January, 1996, the amount or the aggregate amount of the relevant investments made,<[5][5]>Subject to paragraph (b), where in the period—<[5]

[5]>

(I) being a period of 12 months (in paragraph (b) referred to as a “12 month period”) ending on an anniversary of the 22nd day of January, 1996, or

(II) commencing on the 23rd day of January, 1999, and ending on the 5th day of April, 2000 (in paragraph (b) referred to as the “specified period”),

<[5]

[5]>the amount or the aggregate amount of the relevant investments made,<[5] or treated as made, by an allowable investor company, or by such company and all companies (which other companies are referred to in paragraph (b) as “connected companies”) which at any time in that period would be regarded as connected with such company, exceeds [18]>£8,000,000<[18][18]>€10,160,000<[18]

(i) no relief shall be given under this section in respect of the amount of the excess, and

(ii) where there is more than one relevant investment, the inspector or, on appeal, the Appeal Commissioners shall make such apportionment of the relief available as shall be just and reasonable to allocate to each relevant investment a due proportion of the relief available and, where necessary, to grant to each allowable investor company concerned an amount of relief proportionate to the amount of the relevant investment or the aggregate amount of the relevant investments made by it in the period.

(b) No relief shall be given under this section in respect of the amount or the aggregate amount of the relevant investments (in this paragraph referred to as “the total amount”) made by an allowable investor company and its connected companies—

(i) to the extent that the amount of the relevant investment, or the total amount made in any one qualifying company, exceeds [19]>£3,000,000<[19][19]>€3,810,000<[19], and

(ii) where in any 12 month period[6]>, or in the specified period,<[6] the total amount exceeds [20]>£3,000,000<[20][20]>€3,810,000<[20], to the extent that the excess comprises a relevant investment or relevant investments made in a qualifying company to enable the company to produce a film, the total cost of production of which exceeds [21]>£4,000,000<[21][21]>€5,080,000<[21].

(5) Subject to this section, where in any year of assessment a qualifying individual makes a relevant investment, the individual shall, on making a claim in that behalf, be given a relevant deduction from his or her total income for that year of assessment.

(6) A relevant deduction shall not be given under this section in respect of any relevant investment made by a qualifying individual in a qualifying company in any year of assessment unless the amount of that relevant investment or the total amount of the relevant investments made by the individual in the qualifying company in that year is [27]>[25]>£200<[25][25]>£148<[25]<[27][27]>€250<[27] or more and, for the purposes of this section in the case of a qualifying individual [75]>who is married and is assessed to tax for a year of assessment in accordance with section 1017,<[75][75]>who is married and is assessed to tax for a year of assessment in accordance with section 1017, or who is a civil partner and is assessed to tax for a year of assessment in accordance with section 1031C,<[75] any relevant investment made by the qualifying individual’s [76]>spouse<[76][76]>spouse or civil partner<[76] in the qualifying company in that year of assessment shall be deemed to have been made by the qualifying individual.

(7) A relevant deduction shall not be given to a qualifying individual under this section for a year of assessment to the extent to which the amount of the relevant investment or the total amount of the relevant investments (whether or not made in the same qualifying company) made or treated as made by the individual in that year of assessment exceeds [22]>[26]>£25,000<[26][26]>£18,500<[26]<[22][67]>[22]>€31,750<[22]<[67][67]>€50,000<[67].

(8) Where for any year of assessment a greater relevant deduction would be given to a qualifying individual under this section but for either or both of the following reasons—

(a) an insufficiency of total income, or

(b) the operation of subsection (7),

then, [70]>125 per cent of the relevant deduction<[70][70]>the amount of the relevant deduction<[70] which cannot be given to the individual under this section for either or both of those reasons shall be carried forward to the next year of assessment and shall be treated for the purposes of this section as a relevant investment made by the individual in that next year; but an amount shall not be carried forward to any year of assessment after the year [7]>1998-99<[7][30]>[7]>1999-2000<[7]<[30][44]>[30]>the year of assessment 2004<[30]<[44][64]>[44]>the year of assessment 2008<[44]<[64][72]>[64]>the year of assessment 2012<[64]<[72][72]>the year of assessment 2015<[72].

(9) To the extent that an amount once carried forward to a year of assessment under subsection (8) (and treated as a relevant investment made by a qualifying individual in that year of assessment) gives rise to a relevant deduction which is not deducted from the qualifying individual’s total income for that year of assessment, the amount shall to that extent be carried forward again to the next year of assessment (and treated as a relevant investment made by the individual in that next year), and so on for succeeding years of assessment; but an amount shall not be carried forward to any year of assessment after the year [8]>1998-99<[8][31]>[8]>1999-2000<[8]<[31][45]>[31]>the year of assessment 2004<[31]<[45][65]>[45]>the year of assessment 2008<[45]<[65][73]>[65]>the year of assessment 2012<[65]<[73][73]>the year of assessment 2015<[73].

(10) A relevant deduction under this section shall be given to a qualifying individual for any year of assessment as follows—

(a) in the first instance, in respect of an amount of relevant investment carried forward from an earlier year of assessment in accordance with subsection (8) or (9), and, in respect of such an amount so carried forward, for an earlier year of assessment in priority to a later year of assessment, and

(b) only thereafter, in respect of any other amount of relevant investment in respect of which a relevant deduction is to be given in that year of assessment.

(11) (a) A claim to relief under this section may be allowed at any time after the time specified in paragraph (b) in respect of the payment of a sum to a qualifying company, which, if it is used, within 2 years of its being paid, by the qualifying company for the production of a qualifying film, will be a relevant investment, if all the conditions for relief are or will be satisfied; but the relief shall be withdrawn if, by reason of the happening of any subsequent event including [46]>the revocation by the Minister of a certificate under subsection (2)<[46][46]>the revocation, under subsection (2D), by the Revenue Commissioners of a certificate issued by them under subsection (2A)<[46] or the failure of an event to happen which at the time the relief was given was expected to happen, the company or the individual, as the case may be, making the claim was not entitled to the relief allowed.

(b) The time referred to in paragraph (a) is the time when all of the following events have occurred—

(i) the payment in respect of which relief is claimed has been made, and

(ii) in relation to the qualifying film the principal photography has commenced, the first animation drawings have commenced or the first model movement has commenced, as appropriate.

(12) A claim for relief in respect of a relevant investment in a company shall not be allowed unless it is accompanied by a certificate issued by the company in such form as the Revenue Commissioners may direct and certifying that the conditions for the relief, in so far as they apply to the company and the qualifying film, are or will be satisfied in relation to that investment.

(13) Before issuing a certificate for the purposes of subsection (12), a company shall furnish the authorised officer with—

(a) a statement to the effect that it satisfies or will satisfy the conditions for the relief in so far as they apply in relation to the company and a film,

[47]>

(b) a copy of any notification required to be given to the Minister under subsection (2)(b)(iii),

(c) a copy of the certificate, including a copy of any notice given by the Minister amending, revoking or adding a condition to that certificate, under subsection (2) in respect of the film, and

<[47]

(d) such other information as the Revenue Commissioners may reasonably require.

[32]>

(14) A certificate to which subsection (12) relates shall not be issued without the authority of the authorised officer.

<[32]

[32]>

(14) (a) A certificate referred to in subsection (12) shall not be issued without the approval in writing of the authorised officer and where the authorised officer has not received the information sought under subsection (13)(d), or has reason to believe that the conditions for the relief are not, or will not be, satisfied, the authorised officer shall not give such approval.

(b) Where, in accordance with paragraph (a), the authorised officer does not give the approval referred to in that paragraph, the officer shall issue a determination to that effect and the provisions of section 949 shall apply to such determination as if it were a determination made on a matter referred to in section 864.

<[32]

(15) Any statement under subsection (13) shall—

(a) contain such information as the Revenue Commissioners may reasonably require,

(b) be in such form as the Revenue Commissioners may direct, and

(c) contain a declaration that it is correct to the best of the company’s knowledge and belief.

[68]>

(16) Where a company has issued a certificate for the purposes of subsection (12) or furnished a statement under subsection (13) and either—

(a) the certificate or statement was made fraudulently or negligently, or

(b) the certificate was issued in contravention of subsection (14),

then—

(i) the company shall be liable to a penalty not exceeding [23]>£500<[23][23]>€630<[23] or, in the case of fraud, not exceeding [24]>£1,000<[24][24]>€1,265<[24], and such penalty may, without prejudice to any other method of recovery, be proceeded for and recovered summarily in the like manner as in summary proceedings for the recovery of any fine or penalty under any Act relating to the excise, and

(ii) no relief shall be given under this section and, if any such relief has been given, it shall be withdrawn.

<[68]

[68]>

(16) Where a company has issued a certificate for the purposes of subsection (12) or furnished a statement under subsection (13) and either—

(a) the certificate or statement is false or misleading, or

(b) the certificate was issued in contravention of subsection (14),

then—

(i) the company shall be liable to a penalty of €4,000, and

(ii) no relief shall be given under this section and, if any such relief has been given, it shall be withdrawn.

<[68]

(17) For the purpose of regulations made under section 986, no regard shall be had to the relief unless a claim for it has been duly made and admitted.

(18) An allowable investor company or a qualifying individual shall not be entitled to relief in respect of a relevant investment unless the relevant investment—

(a) has been made for bona fide commercial reasons and not as part of a scheme or arrangement the main purpose or one of the main purposes of which is the avoidance of tax,

(b) has been or will be used in the production of a qualifying film, and

(c) is made at the risk of the allowable investor company or the qualifying individual, as the case may be, and—

(i) in a case where it is made by an allowable investor company, neither the company nor any person who would be regarded as connected with the company, or

(ii) in a case where it is made by a qualifying individual, neither the individual nor any person who would be regarded as connected with the individual,

is entitled to receive any payment in money or money’s worth or other benefit directly or indirectly borne by or attributable to the qualifying company, other than a payment made on an arm’s length basis for goods or services supplied or a payment out of the proceeds of exploiting the film to which the allowable investor company or the qualifying individual, as the case may be, is entitled under the terms subject to which the relevant investment is made.

(19) Where any relief has been given under this section which is subsequently found not to have been due or is to be withdrawn by virtue of subsection (11) or (16), that relief shall be withdrawn by making an assessment to corporation tax or income tax, as the case may be, under Case IV of Schedule D for the accounting period or accounting periods, or the year of assessment or years of assessment, as the case may be, in which relief was given and, notwithstanding anything in the Tax Acts, such an assessment may be made at any time.

(20) (a) In this subsection, “new ordinary shares” means new ordinary shares forming part of the ordinary share capital of a qualifying company which, throughout the period of one year commencing on the date such shares are issued, carry no present or future preferential right to dividends, or to a company’s assets on its winding up, and no present or future preferential right to be redeemed.

(b) Subject to paragraph (d), where an allowable investor company is entitled to relief under this section in respect of any sum or any part of a sum, or would be so entitled on making due claim, as a relevant deduction from its total profits for any accounting period, it shall not be entitled to any relief for that sum or that part of a sum, in computing its income or profits, or as a deduction from its income or profits, for any accounting period under any other provision of the Corporation Tax Acts or the Capital Gains Tax Acts.

(c) Subject to paragraph (d), where a qualifying individual is entitled to relief under this section in respect of any sum or any part of a sum, or would be so entitled on making due claim, as a relevant deduction from his or her total income for any year of assessment—

(i) the individual shall not be entitled to any relief for that sum or that part of a sum in computing his or her total income, or as a deduction from his or her total income, for any year of assessment under any other provision of the Income Tax Acts, and

(ii) so much of that sum or that part of a sum as is equal to the amount of the relevant deduction given in relation thereto shall be treated as a sum which by virtue of section 554, is to be excluded from the sums allowable as a deduction in the computation of gains and losses for the purposes of the Capital Gains Tax Acts.

(d) Where an allowable investor company or a qualifying individual has made a relevant investment by means of a subscription for new ordinary shares of a qualifying company and none of those shares is disposed of by the allowable investor company or the qualifying individual, as the case may be, within one year of their acquisition by that company or that individual, as the case may be, then, the sums allowable as deductions from the consideration in the computation for the purpose of capital gains tax of the gain or loss accruing to the company or the individual, as the case may be, on the disposal of those shares shall be determined without regard to any relief under this section which the company or the individual, as the case may be, has obtained, or would be entitled on due claim to obtain, except that where those sums exceed the consideration they shall be reduced by an amount equal to the lesser of—

(i) the amount of the relevant deduction allowed to the allowable investor company or the qualifying individual, as the case may be, under this section in respect of the subscription for those shares, and

(ii) the amount of the excess;

but, if the disposal of shares is by a qualifying individual and the disposal is within section 1028(5), this paragraph shall not apply.

(21) This section shall apply subject to paragraph 22 of Schedule 32, which contains certain transitional provisions in relation to relief under this section.

[48]>

(22) The Revenue Commissioners shall be responsible for verifying compliance with conditions specified in any certificate issued by the Minister prior to [58]>the day appointed by order made by the Minister for Finance for the coming into operation of this subsection<[58][58]>1 January 2005<[58], where the qualifying company has not, prior to [58]>the day so appointed<[58][58]>1 January 2005<[58], submitted the items, statements, reports or other matters required to be submitted to the Minister under the terms of such certificate to enable the Minister to verify such compliance.

<[48]

<[131]

[228]>

[60]>

(22A) Any functions which are authorised by this section to be performed or discharged by the Revenue Commissioners may be performed or discharged by an authorised officer and any references in this section to the Revenue Commissioners shall, with any necessary modifications, be construed as including references to the authorised officer.

<[60]

<[228]

[48]>

(23) Every regulation made under this section shall be laid before Dáil Éireann as soon as may be after it is made and, if a resolution annulling the regulation is passed by Dáil Éireann within the next 21 days on which Dáil Éireann has sat after the regulation is laid before it, the regulation shall be annulled accordingly, but without prejudice to the validity of anything previously done thereunder.

<[48]

[229]>

(24) (a) This subsection applies to a qualifying film in respect of which the Minister provided the Revenue Commissioners with authorisation under subsection (2), as it stood enacted prior to the commencement of section 26 of the Finance Act 2018.

(b) This section (that is to say, this section as it stands amended by section 26 of the Finance Act 2018) shall apply to a qualifying film to which this subsection applies as if the foregoing authorisation were a certificate issued by the Minister to the producer company under subsection (2) on the date the authorisation was issued.

(25) (a) This subsection applies to a qualifying film in respect of which the Revenue Commissioners had issued a certificate under subsection (2A), as it stood enacted prior to the commencement of section 26 of the Finance Act 2018, but the compliance report required under subsection (2C)(d)(iii), as it stood enacted prior to the commencement of that section 26, has not been provided to the Revenue Commissioners.

(b) This section (that is to say, this section as it stands amended by section 26 of the Finance Act 2018) shall apply to any claim for relief made in respect of a qualifying film to which this subsection applies, and no regard shall be had to the foregoing certificate.

(26) (a) This subsection applies to a payment made by the Revenue Commissioners under subsection (3)(b), as it stood enacted prior to the commencement of section 26 of the Finance Act 2018, but where the compliance report required under subsection (2C)(d)(iii), as it stood enacted prior to the commencement of that section 26, has not been provided to the Revenue Commissioners.

(b) Any amount, to which this subsection applies, paid to a producer company shall be treated as an amount paid on a claim made under subsection (2G)(b)(i) on 1 January 2019.

(27) (a) This subsection applies to financial arrangements which were approved by the Revenue Commissioners under subsection (2CA), as it stood enacted prior to the commencement of section 26 of the Finance Act 2018.

(b) Notwithstanding any such approval, a company shall not be a producer company if the financial arrangements to which this subsection applies contravene subsection (2C)(b).

<[229]

[145]>

1 OJ No. C249, 31.7.2014, p. 1

<[145]

[167]>

2 OJ No. C332, 15.11.2013, p 1

<[167]

[1]

[-] [+]

Substituted by FA98 s32(1)(a). This section shall apply as on and from the 6th day of April, 1997.

[2]

[-] [+]

Substituted by FA98 s32(1)(b). This section shall apply as on and from the 6th day of April, 1997.

[3]

[-] [+]

Substituted by FA99 s61(a)(i).

[4]

[-] [+]

Substituted by FA99 s61(a)(ii).

[5]

[-] [+] [+] [+]

Substituted by FA99 s61(b)(i).

[6]

[+]

Inserted by FA99 s61(b)(ii).

[7]

[-] [+]

Substituted by FA99 s61(c).

[8]

[-] [+]

Substituted by FA99 s61(d).

[9]

[-] [+]

Substituted by FA00 s48(1)(a)(i). With effect from 20 July 2000 per SI 258 of 2000.

[10]

[-] [+]

Substituted by FA00 s48(1)(a)(ii). This section shall have effect from such day as the Minister for Finance may appoint by order. With effect from 20 July 2000 per SI 258 of 2000.

[11]

[-] [+]

Substituted by FA00 s48(1)(b). This section shall have effect from such day as the Minister for Finance may appoint by order. With effect from 20 July 2000 per SI 258 of 2000.

[12]

[-] [+]

Substituted by FA01 sched5.

[13]

[-] [+]

Substituted by FA01 sched5.

[14]

[-] [+]

Substituted by FA01 sched5.

[15]

[-] [+]

Substituted by FA01 sched5.

[16]

[-] [+]

Substituted by FA01 sched5.

[17]

[-] [+]

Substituted by FA01 sched5.

[18]

[-] [+]

Substituted by FA01 sched5.

[19]

[-] [+]

Substituted by FA01 sched5.

[20]

[-] [+]

Substituted by FA01 sched5.

[21]

[-] [+]

Substituted by FA01 sched5.

[22]

[-] [+]

Substituted by FA01 sched5.

[23]

[-] [+]

Substituted by FA01 sched5.

[24]

[-] [+]

Substituted by FA01 sched5.

[25]

[-] [+]

Substituted by FA01 sched2(23)(a). Shall apply only as respects the year of assessment 2001.

[26]

[-] [+]

Substituted by FA01 sched2(23)(b). Shall apply only as respects the year of assessment 2001.

[27]

[-] [+]

Substituted by FA02 sched6(3)(k). Shall be deemed to have come into force and take effect as on and from 1 January 2002.

[28]

[-] [+]

Substituted by FA03 s58(1)(a). Applies with effect from the date of the passing of this Act. FA03 28 March 2003

[29]

[-] [+]

Substituted by FA03 s58(1)(b). This section is deemed to have applied as on and from 1 January 2002.

[30]

[-] [+]

Substituted by FA03 s58(1)(c). This section is deemed to have applied as on and from 20 July 2000.

[31]

[-] [+]

Substituted by FA03 s58(1)(d). This section is deemed to have applied as on and from 20 July 2000.

[32]

[-] [+]

Substituted by FA03 s58(1)(e). Applies with effect from the date of the passing of this Act. FA03 28 March 2003

[33]

[+]

Inserted by FA04 s28(1)(a)(i). With effect from 1 January 2005 per SI 814 of 2004.

[34]

[-] [+]

Substituted by FA04 s28(1)(a)(ii). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[35]

[-] [+]

Substituted by FA04 s28(1)(a)(iii). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[36]

[-] [+]

Substituted by FA04 s28(1)(a)(iv). With effect from 1 January 2005 per SI 814 of 2004.

[37]

[-] [+]

Substituted by FA04 s28(1)(a)(v). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[38]

[-] [+]

Substituted by FA04 s28(1)(a)(vi)(I). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[39]

[-] [+]

Substituted by FA04 s28(1)(a)(vi)(II). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[40]

[-] [-] [+]

Substituted by FA04 s28(1)(b)(i). With effect from 1 January 2005 per SI 814 of 2004.

[41]

[-] [+]

Substituted by FA04 s28(1)(b)(ii). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[42]

[-]

Deleted by FA04 s28(1)(b)(iii). With effect from 1 January 2005 per SI 814 of 2004.

[43]

[+]

Inserted by FA04 s28(1)(c). With effect from 1 January 2005 per SI 814 of 2004.

[44]

[-] [+]

Substituted by FA04 s28(1)(d). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[45]

[-] [+]

Substituted by FA04 s28(1)(e). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[46]

[-] [+]

Substituted by FA04 s28(1)(f). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[47]

[-]

Deleted by FA04 s28(1)(g). This section shall come into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions. With effect from 1 January 2005 per SI 814 of 2004.

[48]

[+] [+]

Inserted by FA04 s28(1)(h). With effect from 1 January 2005 per SI 814 of 2004. Note: FA13 s21 comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or for different provisions.

[49]

[-]

Deleted by FA05 s36(a).

[50]

[-]

Deleted by FA05 s36(b)(i).

[51]

[-] [+]

Substituted by FA05 s36(b)(ii).

[52]

[-] [+]

Substituted by FA05 s36(b)(iii).

[53]

[+]

Inserted by FA05 s36(b)(iv).

[54]

[-]

Inserted by FA05 s36(c)(i).

[55]

[+]

Inserted by FA05 s36(c)(ii).

[56]

[-]

Deleted by FA05 s36(d)(i).

[57]

[+]

Inserted by FA05 s36(d)(ii).

[58]

[-] [+] [-] [+]

Substituted by FA05 s36(e).

[59]

[-] [+]

Substituted by FA06 s18(1)(a). Has effect on such day as the Minister for Finance may by order appoint. With effect from 18 May 2006 per SI 256 of 2006.

[60]

[+]

Inserted by FA06 s18(1)(b). With effect from 18 May 2006 per SI 256 of 2006.

[61]

[-] [+]

Substituted by FA07 sched2(1)(o). Has effect as on and from 2 April 2007

[62]

[-] [+]

Substituted by FA08 s32(1)(a). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[63]

[-] [+]

Substituted by FA08 s32(1)(b). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[64]

[-] [+]

Substituted by FA08 s32(1)(c). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[65]

[-] [+]

Substituted by FA08 s32(1)(d). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[66]

[-] [+]

Substituted by F(No.2)A08 s28(1)(a). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[67]

[-] [+]

Substituted by F(No.2)A08 s28(1)(b). This section comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[68]

[-] [+]

Substituted by F(No.2)A08 sched5(part2)(1)(c). The enactments specified in Schedule 5 are amended or repealed to the extent and manner specified in that Schedule and, unless the contrary is stated, shall come into effect after the passing of this Act.

[69]

[-] [+]

Substituted by FA10 s38(a). Deemed to have come into force and takes effect as on and from 1 January 2010.

[70]

[-] [+]

Substituted by FA10 s38(b). Deemed to have come into force and takes effect as on and from 1 January 2010.

[71]

[-] [+]

Substituted by FA11 s32(1)(a). Comes into operation on such day as the Minister for Finance may by order appoint.

[72]

[-] [+]

Substituted by FA11 s32(1)(b). Comes into operation on such day as the Minister for Finance may by order appoint.

[73]

[-] [+]

Substituted by FA11 s32(1)(c). Comes into operation on such day as the Minister for Finance may by order appoint.

[74]

[-] [+]

Substituted by FA11 sched3(1)(e). Has effect as on and from 6 February 2011.

[75]

[-] [+]

Substituted by F(No.3)A11 sched1(120).

[76]

[-] [+]

Substituted by F(No.3)A11 sched1(121).

[77]

[+]

Inserted by FA12 s24(a). Deemed to have come into force and takes effect on and from 1 January 2012.

[78]

[-] [+]

Substituted by FA12 s24(b). Deemed to have come into force and takes effect on and from 1 January 2012.

[79]

[+]

Inserted by FA12 s24(c). Deemed to have come into force and takes effect on and from 1 January 2012.

[80]

[-] [+]

Substituted by FA12 s24(d). Deemed to have come into force and takes effect on and from 1 January 2012.

[81]

[-] [+]

Substituted by FA12 s24(e). Deemed to have come into force and takes effect on and from 1 January 2012.

[82]

[-]

Deleted by FA12 s24(f). Deemed to have come into force and takes effect on and from 1 January 2012.

[83]

[-]

Deleted by FA12 s24(g). Deemed to have come into force and takes effect on and from 1 January 2012.

[84]

[-] [+]

Substituted by FA12 s24(h). Deemed to have come into force and takes effect on and from 1 January 2012.

[85]

[+]

Inserted by FA12 s24(i). Deemed to have come into force and takes effect on and from 1 January 2012.

[86]

[+]

Inserted by FA12 s24(j). Deemed to have come into force and takes effect on and from 1 January 2012.

[87]

[-] [+]

Substituted by FA12 s24(k). Deemed to have come into force and takes effect on and from 1 January 2012.

[88]

[+]

Inserted by FA12 s24(l). Deemed to have come into force and takes effect on and from 1 January 2012.

[89]

[-]

Deleted by FA13 s21(1)(a).

[90]

[-] [+]

Substituted by FA13 s21(1)(b).

[91]

[-] [+]

Substituted by FA13 s21(1)(c).

[92]

[-]

Deleted by FA13 s21(1)(d).

[93]

[-] [+]

Substituted by FA13 s21(1)(e).

[94]

[-]

Deleted by FA13 s21(1)(f).

[95]

[-]

Deleted by FA13 s21(1)(g).

[96]

[-]

Deleted by FA13 s21(1)(h).

[97]

[+] [+]

Inserted by FA13 s21(1)(i).

[98]

[-] [+] [-] [+]

Substituted by FA13 s21(1)(j)(i).

[99]

[-]

Deleted by FA13 s21(1)(j)(ii).

[100]

[-] [+] [-] [+]

Substituted by FA13 s21(1)(k).

[101]

[-] [+]

Substituted by FA13 s21(1)(l).

[102]

[-] [+]

Substituted by FA13 s21(1)(m).

[103]

[-] [+]

Substituted by FA13 s21(1)(m).

[104]

[-] [+]

Substituted by FA13 s21(1)(m).

[105]

[+]

Inserted by FA13 s21(1)(n).

[106]

[-] [+]

Substituted by FA13 s21(1)(o).

[107]

[+]

Inserted by FA13 s21(1)(p).

[108]

[-] [+]

Substituted by FA13 s21(1)(q).

[109]

[-] [+]

Substituted by FA13 s21(1)(r).

[110]

[-] [+]

Substituted by FA13 s21(1)(s).

[111]

[+]

Inserted by FA13 s21(1)(t).

[112]

[+]

Inserted by FA13 s21(1)(u)(i).

[113]

[+]

Inserted by FA13 s21(1)(u)(ii).

[114]

[-] [+]

Substituted by FA13 s21(1)(u)(iii).

[115]

[-]

Deleted by FA13 s21(1)(v).

[116]

[-] [+]

Substituted by FA13 s21(1)(w).

[117]

[+]

Inserted by FA13 s21(1)(x).

[118]

[-] [+]

Substituted by FA13 s21(1)(y).

[119]

[-] [+]

Substituted by FA13 s21(1)(z).

[120]

[-] [+]

Substituted by FA13 s21(1)(aa).

[121]

[-] [+]

Substituted by FA13 s21(1)(ab).

[122]

[-] [+]

Substituted by FA13 s21(1)(ac)(i).

[123]

[-] [+]

Substituted by FA13 s21(1)(ac)(ii).

[124]

[-] [+]

Substituted by FA13 s21(1)(ac)(ii).

[125]

[-]

Deleted by FA13 s21(1)(ac)(iii).

[126]

[-] [+]

Substituted by FA13 s21(1)(ac)(iv).

[127]

[+]

Inserted by FA13 s21(1)(ad).

[128]

[-] [+]

Substituted by FA13 s21(1)(ae).

[129]

[-] [+]

Substituted by FA13 s21(1)(af).

[130]

[+]

Inserted by FA13 s21(1)(ag).

[131]

[-]

Deleted by FA13 s21(1)(ah).

[132]

[-] [+]

Substituted by F(No.2)A13 s24(1). Comes into operation on such day as the Minister for Finance may by order appoint.

[133]

[-]

Deleted by FA14 s24(1)(a). Comes into operation on such day as the Minister for Finance may appoint by order.

[134]

[+]

Inserted by FA14 s24(1)(b)(i)(I). Comes into operation on such day as the Minister for Finance may appoint by order.

[135]

[-]

Deleted by FA14 s24(1)(b)(i)(II). Comes into operation on such day as the Minister for Finance may appoint by order.

[136]

[-] [+]

Substituted by FA14 s24(1)(b)(i)(III). Comes into operation on such day as the Minister for Finance may appoint by order.

[137]

[+]

Inserted by FA14 s24(1)(b)(i)(IV). Comes into operation on such day as the Minister for Finance may appoint by order.

[138]

[-] [+]

Substituted by FA14 s24(1)(b)(ii). Comes into operation on such day as the Minister for Finance may appoint by order.

[139]

[-] [+]

Substituted by FA14 s24(1)(c)(i). Comes into operation on such day as the Minister for Finance may appoint by order.

[140]

[-]

Deleted by FA14 s24(1)(c)(ii). Comes into operation on such day as the Minister for Finance may appoint by order.

[141]

[-] [+]

Substituted by FA15 s17(1)(a)(i). Comes into operation on 1 January 2016.

[142]

[-] [+]

Substituted by FA15 s17(1)(a)(ii). Comes into operation from 1 May 2016 per S.I. 205/2016.

[143]

[-] [+]

Substituted by FA15 s17(1)(b). Applies for the year of assessment 2016 and subsequent years.

[144]

[-] [+]

Substituted by FA17 sched2(1)(q). Deemed to have come into operation on 1 June 2015.

[145]

[+] [+] [+] [+] [+] [+]

Inserted by FA18 s26(1)(a)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[146]

[-]

Deleted by FA18 s26(1)(a)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[147]

[-] [+]

Substituted by FA18 s26(1)(a)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[148]

[-] [+]

Substituted by FA18 s26(1)(a)(iv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[149]

[-]

Deleted by FA18 s26(1)(a)(v)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[150]

[-]

Deleted by FA18 s26(1)(a)(v)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[151]

[-]

Deleted by FA18 s26(1)(a)(v)(III). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[152]

[-]

Deleted by FA18 s26(1)(a)(v)(IV)(A). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[153]

[-] [+]

Substituted by FA18 s26(1)(a)(v)(IV)(B). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[154]

[+]

Inserted by FA18 s26(1)(a)(v)(V). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[155]

[-] [+]

Substituted by FA18 s26(1)(a)(vi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[156]

[-]

Deleted by FA18 s26(1)(a)(vii)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[157]

[-] [+]

Substituted by FA18 s26(1)(a)(vii)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[158]

[-] [+]

Substituted by FA18 s26(1)(a)(viii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[159]

[+]

Inserted by FA18 s26(1)(b). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[160]

[-] [+]

Substituted by FA18 s26(1)(c)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[161]

[-] [+]

Substituted by FA18 s26(1)(c)(ii)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[162]

[-] [+]

Substituted by FA18 s26(1)(c)(ii)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[163]

[+]

Inserted by FA18 s26(1)(c)(ii)(III). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[164]

[-] [+]

Substituted by FA18 s26(1)(c)(ii)(IV). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[165]

[-] [+]

Substituted by FA18 s26(1)(c)(ii)(V). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[166]

[-] [+]

Substituted by FA18 s26(1)(c)(ii)(VI). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[167]

[+] [+]

Inserted by FA18 s26(1)(c)(ii)(VII). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[168]

[-]

Deleted by FA18 s26(1)(d)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[169]

[-] [+]

Substituted by FA18 s26(1)(d)(ii)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[170]

[-] [+]

Substituted by FA18 s26(1)(d)(ii)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[171]

[-] [+]

Substituted by FA18 s26(1)(d)(ii)(III). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[172]

[+]

Inserted by FA18 s26(1)(d)(ii)(IV). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[173]

[-]

Deleted by FA18 s26(1)(d)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[174]

[-]

Deleted by FA18 s26(1)(d)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[175]

[-]

Deleted by FA18 s26(1)(d)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[176]

[-] [+]

Substituted by FA18 s26(1)(d)(iv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[177]

[-]

Deleted by FA18 s26(1)(d)(v). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[178]

[-]

Deleted by FA18 s26(1)(d)(v). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[179]

[+]

Inserted by FA18 s26(1)(d)(vi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[180]

[-] [+]

Substituted by FA18 s26(1)(e)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[181]

[-] [+]

Substituted by FA18 s26(1)(e)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[182]

[+]

Inserted by FA18 s26(1)(e)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[183]

[-] [+]

Substituted by FA18 s26(1)(f)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[184]

[-]

Deleted by FA18 s26(1)(f)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[185]

[-]

Deleted by FA18 s26(1)(f)(iii)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[186]

[+]

Inserted by FA18 s26(1)(f)(iii)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[187]

[-] [+]

Substituted by FA18 s26(1)(f)(iv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[188]

[+]

Inserted by FA18 s26(1)(f)(v). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[189]

[-] [+]

Substituted by FA18 s26(1)(f)(vi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[190]

[+]

Inserted by FA18 s26(1)(f)(vii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[191]

[-] [+]

Substituted by FA18 s26(1)(f)(viii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[192]

[-] [+]

Substituted by FA18 s26(1)(f)(ix). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[193]

[-] [+]

Substituted by FA18 s26(1)(f)(x). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[194]

[-]

Deleted by FA18 s26(1)(f)(xi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[195]

[-]

Deleted by FA18 s26(1)(g). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[196]

[-]

Deleted by FA18 s26(1)(g). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[197]

[-] [+]

Substituted by FA18 s26(1)(h)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[198]

[-] [+]

Substituted by FA18 s26(1)(h)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[199]

[-]

Deleted by FA18 s26(1)(h)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[200]

[-]

Deleted by FA18 s26(1)(h)(iv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[201]

[-] [+]

Substituted by FA18 s26(1)(h)(v). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[202]

[-]

Deleted by FA18 s26(1)(h)(vi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[203]

[-] [+]

Substituted by FA18 s26(1)(h)(vii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[204]

[-] [+]

Substituted by FA18 s26(1)(h)(viii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[205]

[-] [+]

Substituted by FA18 s26(1)(h)(ix). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[206]

[-] [+]

Substituted by FA18 s26(1)(h)(x)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[207]

[-] [+]

Substituted by FA18 s26(1)(h)(x)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[208]

[-] [+]

Substituted by FA18 s26(1)(h)(x)(III). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[209]

[-] [+]

Substituted by FA18 s26(1)(h)(x)(IV). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[210]

[+]

Inserted by FA18 s26(1)(h)(xi). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[211]

[-]

Deleted by FA18 s26(1)(h)(xii)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[212]

[-] [+]

Substituted by FA18 s26(1)(h)(xii)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[213]

[+]

Inserted by FA18 s26(1)(h)(xiii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[214]

[-]

Deleted by FA18 s26(1)(h)(xiv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[215]

[-] [+]

Substituted by FA18 s26(1)(h)(xv). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[216]

[-]

Deleted by FA18 s26(1)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[217]

[+]

Inserted by FA18 s26(1)(j). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[218]

[-] [+]

Substituted by FA18 s26(1)(k)(i). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[219]

[-] [+]

Substituted by FA18 s26(1)(k)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[220]

[-]

Deleted by FA18 s26(1)(k)(iii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[221]

[-] [+]

Substituted by FA18 s26(1)(l)(i)(I). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[222]

[-] [+]

Substituted by FA18 s26(1)(l)(i)(II). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[223]

[-] [+] [-] [+]

Substituted by FA18 s26(1)(l)(i)(III)(A). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[224]

[-] [+]

Substituted by FA18 s26(1)(l)(i)(III)(B). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[225]

[+]

Inserted by FA18 s26(1)(l)(i)(IV). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[226]

[-] [+]

Substituted by FA18 s26(1)(l)(ii). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[227]

[-] [+]

Substituted by FA18 s26(1)(m). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[228]

[-]

Deleted by FA18 s26(1)(n). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.

[229]

[+]

Inserted by FA18 s26(1)(o). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.