Taxes Consolidation Act 1997 section 144

Distributions out of profits from trading within Shannon Airport

Section 144 sets out how distributions made out of profits from trading operations within Shannon Airport (which were exempted from corporation tax under the now-spent Shannon relief) are treated when paid out by a company.

• Shannon relief exempted certain trading profits earned in the Shannon Airport Zone from corporation tax; the relief is no longer available after 6 April 1990, but the distribution rules in this section continue to apply to historic reserves.
• A distribution made partly out of exempted Shannon income and partly out of other profits is split and treated as two separate distributions.
• Where the recipient of an exempted distribution is another company, that distribution is itself treated as exempted Shannon income in its hands; an individual recipient gets no tax credit and remains fully liable to income tax.
• Dividend statements must identify exempted distributions, and a formula determines the distributable income of an accounting period for attribution purposes.