Revenue Note for Guidance

The content shown on this page is a Note for Guidance produced by the Irish Revenue Commissioners. To view the section of legislation to which the Note for Guidance applies, click the link below:

Revenue Note for Guidance

751 Traders other than dealers in securities


This section contains provisions corresponding to those against dividend-stripping (sections 752 and 753) and ensures that measures against “cum div” and “ex div” dealings also apply to non-financial entities.


(1) In determining any tax repayment due to a person who is not a dealer in securities in respect of any trading income, any interest computed in accordance with Schedule 21 and any tax paid on that interest is to be disregarded. In addition, these provisions are carried through for corporation tax purposes.

(2) There is also provision to prevent a company, not engaged in a financial trade, from setting off tax paid on such interest received against any withholding tax deducted under section 238 on any annual payments made by it.

Relevant Date: Finance Act 2021