Taxes Consolidation Act 1997 section 1039

Restrictions on chargeability

Section 1039 protects non-resident persons from being charged to Irish tax through brokers, general commission agents, or other intermediaries in certain circumstances.

• A non-resident cannot be made chargeable to tax in the name of a broker or general commission agent through whom sales or transactions are carried out.
• The protection also extends to any agent who is not an authorised person carrying on the regular agency of the non-resident.
• An agent who is not otherwise chargeable under the non-resident agency rules in this Chapter is similarly excluded.
• Transactions between a non-resident and other non-residents do not, by themselves, make that person chargeable in the name of a resident agent.