Vol. 424 No. 10
59 Mr. Kenny asked the Minister for Finance if he considers that the production and sale of a newspaper, together with the advertising revenue derived as a result of the production, should be treated as a sale of goods within the meaning of Section 39 of the Finance Act, 1980; and if he will make a statement on the matter.
Chapter VI of the Finance Act, 1980, provides that corporation tax payable by a company, in so far as it is referable to income from the sale of goods manufactured in the State, is to be reduced by three-quarters. Newspapers are manufactured products and the corporation tax on the income arising to a company from the sale of those manufactured products may be reduced under the provisions of Chapter VI.
Companies involved in the production of a newspaper have, in general two aspects to their business. These are the manufacture of the newspaper and the provision of advertising services. Income from the provision of advertising services is not income from the sale of manufactured goods. Accordingly, corporation tax payable by a company in respect of income from the provision of such services does not fall to be reduced under Chapter VI. This is the situation with regard to all print media.
The foregoing interpretation of Chapter VI has been challenged on a number of occasions. Section 46 of the Finance Act, 1992, removes any doubt in this matter by confirming that income from the provision of advertising services in the course of the production of a newspaper, magazine or similar product is not to be regarded as income from the sale of manufactured goods.
