Taxes Consolidation Act 1997 section 1014

Tax treatment of profits, losses and capital gains arising from activities of a European Economic Interest Grouping (EEIG)

Section 1014 provides for the tax treatment of European Economic Interest Groupings (EEIGs), ensuring that profits, losses and capital gains of an EEIG are not taxed at the grouping level but are instead attributed to its individual members under the partnership rules.

• An EEIG is a transnational business entity formed under EU Council Regulation 2137/85 and the corresponding Irish regulations, composed of businesses from one or more EU Member States joining together for common purposes.
• The EEIG itself is not chargeable to income tax, corporation tax or capital gains tax on its profits or gains, nor is it entitled to claim relief for any losses it sustains.
• Instead, the partnership provisions of Part 43 apply to the EEIG's activities, so that profits, losses and capital gains are attributed to the individual members of the grouping and taxed or relieved in their hands.
• When applying the partnership rules, the EEIG formation contract is treated as the partnership agreement, each EEIG member is treated as a partner, and functions normally performed by the precedent acting partner are performed by the grouping itself.