Revenue Note for Guidance
Section 530G sets out the conditions that a subcontractor must satisfy in order to receive a zero rate determination from the Revenue Commissioners.
(1) This section applies, subject to subsections (2) and (3), to a person who satisfies the Revenue Commissioners that the person -
(1)(a) Is or is about to become a subcontractor carrying out relevant operations.
(1)(b) Carries on a business from a permanent building and has the necessary equipment and facilities for the business.
(1)(c) Keeps or will keep adequate records as required by section 886(2).
(1)(d) Has throughout the previous 3 years complied with all their tax obligations in relation to the payment or remittance of taxes, the filing of returns and the supply of accounts or other information to a Revenue officer.
(1)(e) In the case of a subcontractor who was resident outside of the state during the 3 years, has complied with obligations comparable to paragraphs (c) and (d) in the country in which they were resident.
(2) This section does not apply to a subcontractor who -
(2)(a) Is a partner, unless the partnership has complied with and the Revenue Commissioners are satisfied they will continue to comply with the obligations in subsection (1).
(2)(b) Is a company, unless each director and any beneficial owner of more than 15 per cent of the ordinary share capital of the company, are persons to which paragraphs (c) and (d) of subsection (1) refer.
(2)(c) Is a proprietary director of a company engaged in the business of carrying out relevant contracts unless the company is a person to whom paragraphs (c) and (d) of subsection (1) refer.
(2)(d) The Revenue Commissioners consider unlikely to comply in the future with the obligations referred to in paragraph (c) or (d) of subsection (1).
(2)(e) Is carrying out similar relevant operations which were previously, or are being, carried out by another connected person (a company or partnership), unless the connected person satisfies the criteria in relation to record keeping and compliance for the zero rate as set out above.
(3) This section also applies to a subcontractor who satisfies the Revenue Commissioners s that the matters referred to in subsection (1) or (2), should be disregarded for the purposes of this section.
Relevant Date: Finance Act 2025