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Taxes Consolidation Act, 1997 (Number 39 of 1997)


267K Miscellaneous.

(1) Sections 267G, 267H, 267I and 267J shall not apply to interest or royalties unless it can be shown that the payment of the interest or royalties was made for bona fide commercial reasons and does not form part of any arrangement or scheme of which the main purpose or one of the main purposes is avoidance of liability to income tax, corporation tax or capital gains tax.

(2) Where a company which—

(a) is entitled to receive a payment of interest or royalties from any person, and

(b) had received from that person a payment of interest or royalties which was exempt from tax in accordance with the Directive,

ceases to fulfil the requirements specified in the Directive for exemption to apply, the company shall without delay inform that person that it has so ceased.




Inserted by FA04 sched1.