Taxes Consolidation Act 1997 section 451

Treatment of income and gains of certain trading operations carried on in Custom House Docks Area from investments held outside the State

Section 451 capped the rate of Irish tax at 10 per cent on foreign-source income and gains arising on investments held by foreign life assurance and foreign unit trust businesses operating in the Custom House Docks Area.

• The cap applied only to qualifying trading operations carried on in the Custom House Docks Area whose policy holders or unit holders were resident outside the State.
• Irish income tax, corporation tax and capital gains tax on foreign investment returns were limited to a maximum rate of 10 per cent, before any credit for foreign tax.
• Foreign life assurance policies could not grant additional contractual rights or substitution options exercisable while the holder was Irish resident.
• The section was deleted by Finance Act 2012 as part of the wind-down of the Custom House Docks Area special tax regime.