Revenue Note for Guidance

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Revenue Note for Guidance

827 Application to corporation tax of arrangements made in relation to corporation profits tax under old law

This section provides that any arrangements made under section 361 of the Income Tax Act 1967 (that section was the predecessor of section 826) or any earlier corresponding provision in relation to corporation profits tax apply to corporation tax in the same way as they were intended to apply to corporation profits tax and not as they apply in relation to income tax. However, this is subject to any arrangements made after 31 March 1976 which make other requirements. The section has no effect on Revenue’s right to disclose information to authorised officers of territories with which double taxation arrangements are in force under section 826(7) or of the procedures for claims, and appeals, relating to credit for foreign tax under paragraph 12 of Schedule 24.

Relevant Date: Finance Act 2021