Revenue Precedent

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Revenue Precedents

Does making and erecting of aluminum gutters qualify under section 443 TCA 1997? Manufacture is a question of fact to be determined by the Inspector; “erection” is “ancillary” construction operation. RLS 319.4(2

(1) Whether the manufacture of doors, window frames, stairs, kitchen and bar units and similar items qualifies under section 443? Yes; (2) Whether installation is construction under section 444? Yes. RLS 319.4(4)

Whether portable cabins including floor coverings, blinds, plumbing and delivery qualify under section 443 and whether section 444 applies? Cabins qualify; floor coverings and blinds can be included on “de minimus” basis; delivery can be included as “goods” if not seperately charged; plumbing is a construction operation. RLS 319.4(3)

Manufacture supply and laying of tarmacadam: whether qualifies: section 443? Apportion to exclude laying which is a “construction” operation; otherwise qualifies. RLS 319.4(1)

Manufacture and installation of refrigeration and ventilation units for industry: whether qualifying; section 443. whether “construction” for section 444; when “construction” begins? Manufacture qualifies; installation is “construction"; “construction” begins when materials are brought on site. RLS 319.4