Stamp Duties Consolidation Act 1999 section 126

Certain statements of interest

Section 126 imposed a stamp duty levy on interest received by companies under so-called "section 84" loans, operating as an anti-avoidance measure against a corporation tax planning device.

  • The levy applied to interest that was treated as a distribution under specific subparagraphs of TCA 1997 section 130(2)(d).
  • Lenders had to deliver twice-yearly statements to the Revenue Commissioners within 30 days of 31 January and 31 July.
  • Stamp duty was charged at 12% of the relevant interest, reduced to 8% where the interest yielded less than 6% per annum.
  • Interest at 2.5% per month accrued on late delivery of statements or late payment of duty.

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