Company rental income & directors remuneration

DB74

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Company A has trading income & rental income. What portion of directors remuneration can be treated as relating to the rental income? From years ago I'm pretty sure it's 10% but can't find anything on it on the web.
 
I think it's what portion of their time do they spend dealing with the properties subject to a 10% / 15% limit.

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Thanks Joe. The company couldn't really be considered an investment company though so does the 10% rule still stand? TBH you couldn't realistically argue that the directors spend much time on the management on the rental of one property / tenant
 
I'd be saying none of it would be allowable against Case V, and a pretty strong case would have to be presented to convince me otherwise i.e. direct evidence of the level of management involved in generating the rental income.

If you have a look at manual 4.8.3 it contains the 10% concession that Revenue apply to "Investment companies" which have rental income - but this doesn't mean it would apply automatically to a trading company. The presumption there would have to be that the director's duties are primarily in directing the trade of the company.
 
I'd be saying none of it would be allowable against Case V, and a pretty strong case would have to be presented to convince me otherwise i.e. direct evidence of the level of management involved in generating the rental income.

+1

In the majority of cases, a letting by a trading company shouldn't involve much management input by the company directors/management.
 
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