Taxes Consolidation Act 1997 section 446

Certain trading operations carried on in Custom House Docks Area

Section 446 allowed the Minister for Finance to certify specified financial services trading operations carried on in the Custom House Docks Area as "relevant trading operations", so that the qualified company could treat them as the manufacture of goods and access the 10 per cent corporation tax rate under manufacturing relief.

  • The Minister for Finance certified specified financial services activities of a "qualified company" in the Custom House Docks Area as "relevant trading operations", deeming them to be the manufacture of goods in the State for the purposes of the 10 per cent manufacturing relief.
  • Certificates could be issued with or without conditions, and could be revoked where the trade ceased, moved wholly outside the Area, breached conditions, was considered inimical to the development of the Area, or attracted a non-compliance notification from the Central Bank.
  • Qualifying activities had to be carried on in the IFSC for non-residents and covered banking-type services, global money management, dealings in currencies, futures, options, bonds and equities, insurance, fund management, financial processing and clearing, commodity dealing, and supporting computer software.
  • The regime was time-limited: certificates lasted until 31 December 2005 for operations approved on or before 31 July 1998, and until 31 December 2002 for operations approved later; section 446 itself was deleted by the Finance Act 2012.

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