Taxes Consolidation Act 1997 section 44

Exemption from corporation tax of certain securities issued by Minister for Finance

Section 44 provides an exemption from corporation tax on interest earned on government securities held by qualifying companies that are Irish-resident trading subsidiaries or branches of foreign companies based in countries with which Ireland has a double taxation agreement.

• The Minister for Finance may issue government securities on condition that interest arising on those securities is exempt from corporation tax, provided the securities are held continuously from the date of issue by a qualifying company.
• A qualifying company is either an Irish-resident company carrying on a relevant trade (or holding shares in such a company) that is at least 90% owned by a foreign company, or a foreign company carrying on a relevant trade through a branch or agency in Ireland.
• A relevant trade must be carried on wholly or mainly in Ireland but must not consist wholly or partly of banking, insurance, selling goods by retail, or dealing in securities.
• A foreign company is one that is not resident in Ireland and is controlled by a person or persons resident in a country with which Ireland has a double taxation agreement in force under section 826(1).