Revenue Note for Guidance
This section exempts the portion of the Brexit compensation sum which relates to crew payments from income tax and corporation tax in the hands of the licence holder provided that sum is paid to the crew member within 3 months of receipt by the licence holder.
(1)This section applies to a licence holder who is chargeable to tax under Case IV of Schedule D in respect of the crew payment amount.
(2)The crew payment is to be exempt from income tax and corporation tax in the hands of the licence holder and is not to be reckoned in computing income for the purposes of the Tax Acts. It is also exempt from PRSI and USC in the hands of the licence holder.
(3)The crew payment paid to a licence holder shall not be deductible in computing their profits or gains chargeable to tax under Case IV of Schedule D.
(4)A licence holder is not entitled to the exemption above unless the crew payment is paid to the crew member(s) concerned within 3 months of its receipt by the licence holder.
Relevant Date: Finance Act 2024