Taxes Consolidation Act, 1997 (Number 39 of 1997)
1039Restrictions on chargeability.
(1) Nothing in this Chapter shall render a non-resident person chargeable in the name of—
(a) a broker or general commission agent, or
(b) an agent, not being—
(i) an authorised person carrying on the regular agency of the non-resident person, or
(ii) a person chargeable as if that person were an agent in pursuance of this Chapter,
in respect of profits or gains arising from sales or transactions carried out through such a broker or agent.
(2) The fact that a non-resident person executes sales or carries out transactions with other non-residents in circumstances which would make that person chargeable in pursuance of this Chapter in the name of a resident person shall not of itself make that person chargeable in respect of profits arising from those sales or transactions.