Taxes Consolidation Act 1997 section 45

Exemption of non-interest-bearing securities

Section 45 provides a tax exemption for profits arising on the redemption of certain non-interest-bearing government securities, with specific rules limiting the exemption for Irish residents while preserving it for non-resident owners.

  • Profits on redemption of non-interest-bearing securities issued by the Minister for Finance under the Central Fund Act 1965 are exempt from tax, unless the profits form part of trading income.
  • Since 25 January 1984, this exemption no longer applies to Irish residents for discounted government securities such as Exchequer Bills, Exchequer Notes, and Agricultural Commodities Intervention Bills.
  • Non-resident owners remain exempt from tax on any profit from the sale, disposal, or redemption of these discounted government securities.
  • The non-resident exemption does not apply to corporation tax charged on the income of an Irish branch or agency of a non-resident company.

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