Commentary on Sections Overview Overview Section 839: Annual payments payable out of relevant foreign income
3123.This section is based on section 65(1) of ICTA.
3124.By virtue of subsection (3), which refers to a payment that “would have been chargeable” to tax under certain provisions, the range of annual payments falling within condition B is in fact reduced by any that are within the exemption provided by section 727 (certain annual payments by individuals).
3125.Subsection (6) reflects differences in the source legislation between the rules for calculating income arising in the Republic of Ireland and those for calculating other relevant foreign income.