Taxes Consolidation Act 1997 section 449

Credit for foreign tax not otherwise credited

Section 449 provided extra relief, within the manufacturing relief regime, for foreign tax suffered on sales of goods where that foreign tax could not be credited under the normal double tax relief rules.

• Applied where a manufacturing relief company received income from the sale of goods (including computer software and certain other categories treated as sale-of-goods receipts) and suffered foreign tax on those receipts.
• The foreign tax had to correspond to income tax or corporation tax, had not been repaid, and could not be credited under the double tax relief rules in Schedule 24.
• Relief was given by reducing the Irish corporation tax for the period by nine-tenths of the foreign tax suffered, capped at the corporation tax attributable to that sale-of-goods income.
• The section was deleted by Finance Act 2012, alongside the phasing out of the 10 per cent manufacturing relief regime.