Revenue eBrief No. 121/22
03 June 2022
Corporation Tax: Losses in transactions from which income would be chargeable under Case IV or V of Schedule D (section 399 TCA 1997)
Tax and Duty Manual Part 12-03-03 – Corporation Tax: Losses in transactions from which income would be chargeable under Case IV or V of Schedule D (section 399 TCA 1997) – has been updated in section 4. The updates reflect changes introduced in Finance Act 2021 to the taxation of non-Irish resident corporate landlords in receipt of rental income, but who are not trading in Ireland through a branch or agency. These corporate landlords are subject to corporation tax rather than income tax on Irish rental income from 1 January 2022.