Paragraph 4(5) of that Schedule 24 permits a company to allocate certain charges on income as it thinks fit for this purpose. It has been generally accepted that paragraph 4(5) does not permit a company to allocate relevant trading charges on the income in this matter. This financial resolution puts the position beyond doubt. The resolution will be effective as from today. It will apply to, first, all returns for corporation tax, second, all claims to repayment of corporation tax and, third, all claims to reduction of liability to corporation tax made to the Revenue Commissioners from today.

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