Taxes Consolidation Act 1997 section 156

Franked investment income and franked payments

Section 156 defines "franked investment income" and "franked payment" for the purposes of the Corporation Tax Acts.

  • Franked investment income is the amount or value of a distribution received by an Irish resident company from another Irish resident company.
  • A franked payment is the amount or value of a distribution made by an Irish resident company.
  • Franked investment income is not subject to corporation tax but may be liable to the close company surcharge under section 440.
  • A joint election under section 434(3A) allows a close company and its close company recipient to exclude a dividend from the surcharge by treating it as not being franked investment income.

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