Insurance Tax Insight - August 2014

Foreign branch double taxation relief

Statement of Practice - The Revenue Commissioners have recently issued a statement of practice on the calculation of foreign branch double taxation relief in certain situations where timing differences arise regarding the recognition of income at the level of an Irish company, compared with the recognition of the same income at the level of a foreign branch.

Previous practice
In the absence of this statement of practice,broadly, where income is recognised for tax purposes in Ireland in an earlier accounting period than that of the foreign branch territory, no double taxation relief would be available because no double-taxed income would arise in Ireland in the relevant accounting period.

Insurance Tax Insight - August 2014
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