Taxes Consolidation Act 1997 Schedule 22 paragraph 4

Computing profits for Schedule 22

Paragraph 4 sets out how a company's profits for a given period are to be determined for the purposes of Schedule 22, by reducing its income by the taxes borne or payable in that period.

• A company's profits for a specified period are its income (as determined under paragraph 5) reduced by the corporation tax payable for any accounting period falling within that period, including surcharges on undistributed investment, estate, or service company income.
• Tax credits attached to distributions received from Irish-resident companies are treated as corporation tax payable by the receiving company, and are therefore also deducted in arriving at profits.
• References to tax payable mean the tax that would have been payable before any double taxation relief allowed on a credit basis, so that foreign tax already suffered is not double-counted.
• Where a company that is not a security dealer receives a distribution or sells a security, the tax attributable to amounts that would have been trading income of a security dealer (under sections 749 and 752) is excluded from the computation.