Taxes Consolidation Act 1997 Schedule 24 paragraph 11

Assessment

Paragraph 11 provides for additional assessments where income covered by a double taxation arrangement has been under-assessed or where the foreign tax credit allowed is incorrect.

• Where a tax treaty applies and income has not been assessed on its full amount, or the foreign tax credit is wrong, Revenue may raise an additional assessment to correct the position.
• If the income was paid through a paying agent in the State, the additional assessment may be made on the recipient under Case IV of Schedule D.
• The purpose is to ensure that the correct total income is brought into charge and that the proper credit, if any, is given for foreign tax paid.
• In practice, self-assessment rules under Part 41A allow the figures in the original assessment to be amended directly, without the need to raise a formal additional assessment.