The Tax and Duty Manual Part 13-02-06 - Surcharge on undistributed income of service companies - has been updated in respect of Revenue’s view of the activity carried on by a “Management Consultant” in the context of section 441 TCA 1997.

The manual provides that the activity of a management consultant is generally not considered to constitute the carrying on of a profession.

A recent Tax Appeals Commission determination considered the meaning of the word “profession”. The Appeal Commissioner noted the need for some form of regulatory control over those engaged in the profession for a company to be engaged in the “provision of professional services” as envisaged by section 441 TCA 1997.

See Revenue eBrief No. 114/21 for further details.