Taxes Consolidation Act 1997 Schedule 21 paragraph 3

Calculating the appropriate proportion

Paragraph 3 of Schedule 21 sets out how to calculate the "appropriate proportion" of accrued interest that is treated as the income of the first buyer for the purposes of paragraphs 1 and 2, using a formula based on ex-dividend dates on the Dublin Stock Exchange.

  • The appropriate proportion is the fraction of the interest period that had elapsed up to the day before the first buyer purchased the securities, measured from the most recent ex-dividend date to the next ex-dividend date.
  • The "first relevant date" and "second relevant date" are defined as the earliest possible ex-dividend dates for the previous and current interest payments respectively, preventing manipulation of those dates.
  • Where the interest receivable by the first buyer was the very first interest payment on the securities, the calculation runs from the start of the period for which that interest was payable, with a special apportionment where capital was paid up in instalments during that period.
  • For securities not quoted on the official list of the Dublin Stock Exchange, the Appeal Commissioners have power to determine equivalent periods for the purpose of the calculation.

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